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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 1 
 
Cognitive Disability Standards Refresh 
(People with Cognitive-Embodied & Environmental Needs) -  White Paper  
 
 
Preamble 
Cognitive Disability Standards Refresh (ID/ABI)  -  White Paper  
A national, world-best-practice program to professionalise frontline disability practice, 
modernise tribunals and oversight, and hard-wire integrity  -  explicitly covering Intellectual 
Disability (ID) and Acquired Brain Injury (ABI) across the lifespan. 
 
 
Date: 25-09-2025 
 
Prepared by: ZELEN. G  (public-interest submission) 
 
Lodgement recipients: Council of Attorneys-General and relevant Ministers (information only) 
 
Distribution: Public 
  
 
One-line summary (Executive Summary lead): 
 
This white paper unifies ID and ABI into a single, person-first standards upgrade: the 
Integrated Disability Clinician (IDC) workforce; tribunal candour (backed by a Decision 
Support Consultant (DSC) file-vs-field calibration and a short Calibration Memo); Two-Key 
Guardianship (no one decides alone); payment integrity; emergency/justice interface 
standards; restrictive-practice and restraint-reduction governance (least-restrictive by 
default); education uplift; rural parity; and minister-ready ROI - with ID/ABI-specific 
modules for cognition, communication, behaviour, swallowing, fatigue, mental/physical 
health, and rehabilitation/transition-to-community. 
  
 
Language note (person-first umbrella) 
 
“People with cognitive disability” is used throughout as an inclusive, person-first term that expressly 
covers people with intellectual disability (ID), acquired brain injury (ABI) and closely related 
cognitive-communication conditions. Where a distinction matters, the paper names it; otherwise one 
plain term avoids siloed care. 
  
“People with Cognitive-Embodied & Environmental Needs” is a plain-English framing used on the 
cover to signal that support needs arise at the intersection of cognition, the body and the built/social 
environment; it is not a diagnostic label and does not replace “people with cognitive disability” in this 
paper. 
 
Conflicts & independence  -  summary 
  
Prepared pro bono in the public interest. No external funding. No current or recent paid relationships 
with providers, agencies, tribunals, or vendors mentioned in this paper. Templates and schemas are 
released for scrutiny and reuse (see Licence). 
 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 2 
 
Publication notes  -  release v1.0 (25 Sep 2025) 
 
Canonical release 
• Title: Cognitive Disability Standards Refresh (ID/ABI) 
• PDF (canonical): export as tagged PDF/A-2. (PDF is authoritative; DOCX is non-authoritative) 
• Version/date: v1.0  -  25 Sep 2025 
• DOI/URL: https://sites.google.com/view/cognitivedisabilitystandards/home 
 
Licence & reuse 
• Text © 2025 ZELEN. G  -  CC BY 4.0 
• Schemas/templates  -  CC BY 4.0; examples/sample data  -  CC0 1.0; code snippets  -  MIT 
 
Non-reliance / no duty (summary) 
This publication is not legal advice, clinical guidance, or case instruction. Do not rely on it for a specific matter. 
Confirm in-force law/practice notes. Do not delay urgent care awaiting paperwork. Privacy: de-identify, 
suppress <5, no re-ID. Full terms: see Appendix AZ  -  Legal, Risk & Publication Basis. 
 
Lodgement & advocacy  
This publication is lodged with Attorneys-General and relevant Ministers for information only and without 
endorsement. The author does not provide a public inbox and ministerial offices are not the contact point for this 
document. Please use the standard parliamentary or departmental contact forms and include your 
electorate/region. Refer to this paper by title and version (e.g., “Cognitive Disability Standards Refresh 
(ID/ABI), v1.0, 25-09-2025”). 
 
Custodianship (post-publication) 
From v1.0, stewardship transfers to the Custodian of Record (appointed by convening partners). The author 
withdraws from custodial/editorial control. 
 
Errata & updates: Any future changes will be issued as new versions in the public record (see 
https://sites.google.com/view/cognitivedisabilitystandards/home). Individual enquiries will not be answered; 
corrections, if adopted, will appear in release notes. No back-channel exists for correspondence. 
 
Public correspondence: None provided. Policy feedback, if any, should be directed through normal government 
consultations or statutory submissions channels; this document itself does not accept submissions. 
 
Accessibility 
• Tagged PDF and Easy-Read one-pager published with each release. 
 
Data & artefacts (where to find them) 
• Schemas (e-receipt minimum; dashboard template), examples, tiles dictionary. 
• Templates (R&W table, Contradiction Matrix, IRC, registry checklist). 
• Policy tracker (with “last checked” dates). 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Disclaimer  -  non-reliance, scope & custody (v1.0  -  25 Sep 2025) 
 
This publication recommends standards and tools (Two-Key, DSC, IDC). It is not legal advice, clinical guidance, 
or case instructions. Do not rely on it for a specific matter; confirm in-force law, practice notes, and local policy. 
No duty of care is assumed to any person for decisions made using this material. Do not delay urgent care awaiting 
paperwork. De-identify examples; do not attempt re-identification; apply suppression (<5). 
 
From v1.0, stewardship transfers to an independent Custodian of Record; the author withdraws from 
custodial/editorial control. See Appendix AZ  -  Legal, Risk & Publication Basis  -  for full terms (non-reliance/no-
duty wording, privacy, defamation/sub judice hygiene, open-justice cadence, change control, notice-and-takedown, 
and contacts). 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 3 
 
 
 
Table of Contents 
Foreword ................................................................................................................................. 13 
Salute to the Disability Royal Commission  -  and how this paper operationalises it .......... 17 
Design constraints  -  and how the standards meet them............................................................. 17 
Where awareness breaks down today  -  and how this paper closes it ....................................... 18 
What this paper is (status and how to use it) ......................................................................... 20 
From “Direct Care” to a Profession  -  what changes, what carries through ............................ 21 
Coordination, Adjacent, and Operational Licence Classes  -  meet or bridge to the standard22 
Closing the reality gap  -  judiciary & oversight with DSC as the live bridge ........................... 25 
Future-proofing with a simple failsafe: Two-Key Guardianship (no one decides alone). ........ 27 
Executive Summary ................................................................................................................ 34 
White paper basics .......................................................................................................................... 35 
Purpose, Scope and Audience ................................................................................................ 36 
Scope (what’s in) .............................................................................................................................. 36 
Boundaries (what’s out) .................................................................................................................. 37 
Non-negotiables ............................................................................................................................... 38 
Method ..................................................................................................................................... 40 
Open reasons & appeal-ready records hub .................................................................................. 43 
How Ministers can message this..................................................................................................... 44 
Dependencies & risks snapshot (for executive readers)............................................................... 45 
Definitions and Principles ...................................................................................................... 46 
Language conventions (style and usage) ....................................................................................... 48 
Principles (non-negotiables that govern design and delivery)..................................................... 48 
Evidence and Drivers .............................................................................................................. 50 
What the data and lived experience show ..................................................................................... 50 
Root causes ....................................................................................................................................... 50 
Problem Definition .......................................................................................................................... 51 
Problem statement (concise) ........................................................................................................... 54 
System drivers for change .............................................................................................................. 54 
What We Lost and Must Restore ................................................................................................... 54 
Social value lens ............................................................................................................................... 55 
NDIS  -  Interface & Reform Alignment (2025) .................................................................... 57 
Why this matters (and why it hasn’t worked) .............................................................................. 57 
Fast take (read this first)................................................................................................................. 57 
What’s changing (status 2025) ....................................................................................................... 57 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 4 
 
Pros (if implemented well) .............................................................................................................. 58 
Cons / risks (to watch and design around) .................................................................................... 58 
Risks & mitigations (NDIS-specific) .............................................................................................. 59 
Measures & public tiles ................................................................................................................... 59 
Switching & safeguards (NDIS events) ......................................................................................... 60 
Consistent with government directions ......................................................................................... 60 
Standards Overview (how all pieces fit) ................................................................................. 61 
The standards map .......................................................................................................................... 61 
Workforce Standard ....................................................................................................................... 61 
Safety & Restrictive Practices Standard ....................................................................................... 61 
Truth-by-Design Standard ............................................................................................................. 62 
Independent Verification Standard ............................................................................................... 62 
Two-Key Guardianship .................................................................................................................. 62 
Service Model Standards ................................................................................................................ 63 
Equity, First Nations Partnership and Access .............................................................................. 64 
Data, Dashboards and Privacy ....................................................................................................... 64 
Implementation Roadmap .............................................................................................................. 64 
Finance & ROI Case ....................................................................................................................... 65 
Governance, Assurance and Risk .................................................................................................. 66 
Evaluation & Continuous Learning .............................................................................................. 66 
Workforce Standard  -  Integrated Disability Clinician (IDC).............................................. 68 
Purpose & scope .............................................................................................................................. 68 
Role definition (what an IDC is and is not) ................................................................................... 68 
Protected title, statutory levers & anti‑gaming controls .............................................................. 68 
Competency framework (domains) ............................................................................................... 68 
Education & pathways (TAFE, University, RN‑integrated, Bridging) ...................................... 69 
Curriculum map, supervised practise & CPD (higher‑of applied)............................................. 69 
Supervised Practice and Observation............................................................................................ 70 
EPAs (Entrustable Professional Activities) ................................................................................... 70 
Portfolio and renewal cycle ............................................................................................................ 70 
Equivalency & bridging (legacy roles → IDC / licence‑aligned roles) ....................................... 71 
Role-clean mapping - specific (titles → licence) ........................................................................... 71 
Safety gates that RPL cannot waive. ............................................................................................. 71 
Supervised practice bands by legacy stream. ............................................................................... 71 
RN on-ramp and incumbent bridging. .......................................................................................... 71 
Rural & regional enablement ......................................................................................................... 72 
Pricing, wage ladders & incentives (alignment) ........................................................................... 72 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 5 
 
Documentation & artefacts (publishable or auditable) ............................................................... 72 
Metrics & indicators (for dashboards) .......................................................................................... 72 
Governance & licensure .................................................................................................................. 73 
Implementation (pilot → scale) ...................................................................................................... 73 
Interfaces with other standards ..................................................................................................... 73 
Risks & mitigations ......................................................................................................................... 73 
Rural/remote execution rules ......................................................................................................... 74 
Safety & Restrictive Practices Standard ................................................................................. 75 
Purpose and scope ........................................................................................................................... 75 
Definitions (used consistently) ........................................................................................................ 75 
Principles and legal baseline ........................................................................................................... 75 
Restraint hierarchy (summary) ..................................................................................................... 75 
Authorisation and notifications ...................................................................................................... 76 
Timekeeping standard .................................................................................................................... 76 
The 72-hour learning review (mandatory) .................................................................................... 76 
Fade plan (required elements)........................................................................................................ 77 
Hospital/ED handover and medication reconciliation ................................................................. 77 
Primary Care & Health Stewardship ............................................................................................ 77 
Primary Care & Health Stewardship (explicit) ............................................................................ 79 
Roles and responsibilities ................................................................................................................ 79 
Artefacts and data (where templates live) ..................................................................................... 79 
Metrics and indicators (dashboards) ............................................................................................. 80 
Training and competence (IDC alignment) .................................................................................. 80 
Equity, cultural safety and access .................................................................................................. 80 
Technology and environment safeguards...................................................................................... 80 
Risk management, escalation and sanctions ................................................................................. 81 
Interfaces with other standards ..................................................................................................... 81 
Implementation (switch-on order) ................................................................................................. 81 
Truth-by-Design Standard ...................................................................................................... 82 
Purpose and scope ........................................................................................................................... 82 
Principles (what “truth by design” means here) .......................................................................... 82 
Two-party e-receipt (minimum standard) .................................................................................... 82 
Roster-to-claim cross-checks (before payment)............................................................................ 83 
Sanctions ladder (proportionate, publishable) ............................................................................. 83 
Financial Safety & Fiduciary Checks ............................................................................................ 83 
Publication & dashboards (signals people can use) ..................................................................... 84 
Privacy, security and DPIA requirements .................................................................................... 84 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 6 
 
Roles and responsibilities ................................................................................................................ 85 
Metrics and indicators (for dashboards) ....................................................................................... 85 
Implementation (switch-on order) ................................................................................................. 85 
Interfaces with other standards ..................................................................................................... 86 
Risks and mitigations ...................................................................................................................... 86 
Independent Verification Standard - Decision Support Consultant (DSC) ......................... 87 
Purpose & scope .............................................................................................................................. 87 
What independent verification is (and is not) ............................................................................... 87 
Triggers (when a DSC must be engaged) ...................................................................................... 87 
Independence & ethics .................................................................................................................... 87 
Role boundaries & interfaces ......................................................................................................... 88 
Two‑Key interface (decision support) ........................................................................................... 88 
Workflow (intake → enquiry → decision support → publication)............................................. 88 
Artefacts (minimum content & templates) ................................................................................... 88 
Methods & integrity controls ......................................................................................................... 89 
Publication, privacy & dashboards ............................................................................................... 89 
Metrics & indicators ....................................................................................................................... 89 
Governance, registers & sanctions................................................................................................. 90 
Rural & remote enablement ........................................................................................................... 90 
Implementation (pilot → scale) ...................................................................................................... 90 
Interfaces with other standards & roles ........................................................................................ 90 
Appeals & fairness........................................................................................................................... 91 
DSC Education & Pathways (entry, bridging, renewal) .............................................................. 91 
Tribunal/OPG/OPA Practice  -  Candour by Template (worked guidance) ............................. 93 
Publication and privacy .................................................................................................................. 95 
Roles and responsibilities ................................................................................................................ 95 
Metrics and indicators (dashboards) ............................................................................................. 96 
Calibration and quality assurance ................................................................................................. 96 
Interfaces with other standards ..................................................................................................... 96 
Implementation (switch-on order) ................................................................................................. 96 
Risks and mitigations ...................................................................................................................... 97 
Example; Template Baseline Formats ........................................................................................... 97 
Shared Decision Standard  -  Two-Key Guardianship       (No One Decides Alone) ......... 104 
Purpose & scope ............................................................................................................................ 104 
Decision classes (in scope) ............................................................................................................. 104 
Core rule ......................................................................................................................................... 104 
Independence & conflict rules ...................................................................................................... 104 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 7 
 
Emergency pathway (Tier‑0) ........................................................................................................ 105 
Quorum models ............................................................................................................................. 105 
Roles & interfaces .......................................................................................................................... 105 
Artefacts (minimum, one‑page forms wherever possible) ......................................................... 105 
Publication & dashboards ............................................................................................................ 105 
Rural & thin‑market parity.......................................................................................................... 106 
Anti‑collusion & capture guards .................................................................................................. 106 
Implementation (switch‑on order) ............................................................................................... 106 
Compliance & sanctions ............................................................................................................... 106 
Service Model Standards (life in community) ...................................................................... 107 
Purpose and scope ......................................................................................................................... 107 
Principles ........................................................................................................................................ 107 
Minimum requirements (what every plan and week must show) ............................................. 107 
Accessible plans (content and format) ......................................................................................... 107 
Community Access Kits (making ordinary places ready) ......................................................... 108 
Community presence and participation (how we practise) ....................................................... 109 
Coordination independent from provision.................................................................................. 109 
Switching protocol (low-friction change) .................................................................................... 109 
Provider Transition Pack (switching & onboarding) ................................................................ 110 
Skill acquisition in real contexts................................................................................................... 112 
Technology and environment ....................................................................................................... 112 
Justice Interfaces (police, courts, corrections) ............................................................................ 112 
Roles and responsibilities .............................................................................................................. 113 
Documentation and artefacts ....................................................................................................... 114 
Metrics and indicators (dashboards) ........................................................................................... 114 
Interfaces with other standards ................................................................................................... 114 
Risks and mitigations .................................................................................................................... 115 
What Can Go Wrong (Even With Love)  -  Risks to Avoid....................................................... 115 
(For parents, guardians and volunteers  -  a safe baseline) ......................................................... 115 
Equity, First Nations Partnership and Access ..................................................................... 117 
Purpose and scope ......................................................................................................................... 117 
Principles ........................................................................................................................................ 117 
First Nations partnership standard ............................................................................................. 117 
Language and communication access standard (CALD/Auslan/AAC).................................... 118 
Rural and remote delivery standard ........................................................................................... 118 
Minimum equity checks embedded in other standards ............................................................. 119 
Roles and responsibilities .............................................................................................................. 119 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 8 
 
Documentation and artefacts (publishable/auditable) ............................................................... 119 
Metrics and indicators (dashboards) ........................................................................................... 119 
Implementation (switch-on order) ............................................................................................... 120 
Risks and mitigations .................................................................................................................... 120 
Data, Dashboards and Privacy ............................................................................................. 120 
Purpose and scope ......................................................................................................................... 120 
Principles ........................................................................................................................................ 121 
Data domains (minimum sets) ...................................................................................................... 121 
Minimum schema rules (applies to every domain)..................................................................... 121 
DPIA (Data Protection Impact Assessment) ............................................................................... 122 
Access control and security .......................................................................................................... 122 
Publication model (family view vs public tiles)........................................................................... 122 
Performance, KPIs & Public Dashboards (full specification) ................................................... 122 
Data lifecycle .................................................................................................................................. 125 
Analytics and AI (allowed uses and limits) ................................................................................. 125 
Operational guardrails (policy text) ............................................................................................ 125 
Interoperability and APIs ............................................................................................................. 126 
Assistive Technology (AT) & AAC Procurement Spec .............................................................. 126 
Incident response & red-team tests ............................................................................................. 128 
Where to get help / Artefacts & Templates (appendices index) ................................................ 128 
Metrics and indicators (for dashboards) ..................................................................................... 128 
Implementation (switch-on order) ............................................................................................... 128 
Risks and mitigations .................................................................................................................... 128 
Implementation Roadmap (Switch-On Order)..................................................................... 129 
How to use this roadmap .............................................................................................................. 129 
Pilot design (where we start and why) ......................................................................................... 129 
Phase 1  -  0 to 3 months (Switch-on foundations) ...................................................................... 129 
Phase 2  -  3 to 6 months (Operate, measure, adjust) ................................................................. 130 
Phase 3  -  6 to 12 months (Scale and calibrate).......................................................................... 131 
Phase 4  -  12 to 24 months (Statewide adoption and external evaluation) .............................. 132 
Cross-cutting QA & governance (always on).............................................................................. 132 
Critical path & dependencies ....................................................................................................... 133 
Roles and RACI (summary) ......................................................................................................... 133 
Communications plan (minimum) ............................................................................................... 133 
Finance & ROI alignment (spend to save) .................................................................................. 133 
Red-team & rehearsal calendar ................................................................................................... 134 
Exit criteria (when a pilot becomes business-as-usual) .............................................................. 134 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 9 
 
Finance & ROI Case............................................................................................................. 134 
Purpose and frame ........................................................................................................................ 134 
What value we count (benefit classes) ......................................................................................... 134 
What it costs (investment bundles) .............................................................................................. 135 
Cost-benefit method (how the workbook calculates) ................................................................. 135 
Core formulas (transparent and auditable) ................................................................................ 135 
Inputs and sources (traceability).................................................................................................. 136 
Assumptions register (editable ranges) ....................................................................................... 137 
Worked example (illustrative flow; populate with local values) ............................................... 137 
Sensitivity and scenario testing .................................................................................................... 137 
Governance, assurance and publication ...................................................................................... 138 
Distributional impacts (who benefits, who pays) ........................................................................ 138 
Interfaces with other sections ....................................................................................................... 138 
Metrics (dashboard alignment) .................................................................................................... 138 
Risks and mitigations .................................................................................................................... 139 
Governance, Assurance and Risk ......................................................................................... 139 
Purpose and scope ......................................................................................................................... 139 
Governance model (who decides, who delivers, who checks) .................................................... 139 
Lines of assurance (how we know it’s working) ......................................................................... 140 
Decision rights and escalation ...................................................................................................... 140 
Privacy/AI conformance  -  gate criteria ..................................................................................... 140 
Sanctions ladder (governance integration) ................................................................................. 141 
Risk management (register, thresholds, actions) ........................................................................ 141 
Red-team and rehearsal program ................................................................................................ 141 
Stress-Tests & Counter-Capture ................................................................................................. 142 
Whistleblowing and protections ................................................................................................... 142 
Issue management (from detection to verified closure) ............................................................. 142 
Audit and evaluation interfaces ................................................................................................... 143 
Procurement levers and market shaping .................................................................................... 143 
Industrial Relations & Insurance Brief ....................................................................................... 143 
Metrics and indicators (governance dashboard) ........................................................................ 143 
Interfaces with other standards ................................................................................................... 144 
Risks and mitigations (summary) ................................................................................................ 144 
Evaluation & Continuous Learning..................................................................................... 144 
Purpose and scope ......................................................................................................................... 144 
Principles ........................................................................................................................................ 144 
Peer calibration (how we align judgement) ................................................................................ 145 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 10 
 
Quality summaries (what we publish each quarter) .................................................................. 145 
Standard refresh and sunset rules ............................................................................................... 145 
Independent evaluation (external review) ................................................................................... 145 
Research & Evaluation Partnerships .......................................................................................... 146 
Continuous curriculum and tool updates .................................................................................... 146 
Operational Aids  -  Consistency Prompts .................................................................................. 146 
Red-team and rehearsal integration ............................................................................................ 147 
Roles and responsibilities .............................................................................................................. 147 
Where to get help / Artefacts & Templates (appendices index) ................................................ 147 
Metrics and indicators (learning dashboard) ............................................................................. 148 
Implementation (switch-on order) ............................................................................................... 148 
Risks and mitigations .................................................................................................................... 148 
Appendices (indexed) ............................................................................................................ 149 
Appendix A  -  Restraint Hierarchy & Timekeeping Standard ................................................ 149 
Appendix B  -  72-Hour Learning Review Template ................................................................. 152 
Appendix C  -  Fade Plan Template (Restraint-Reduction & Positive Supports) ................... 155 
Appendix D  -  Handover & Medication Reconciliation Pack .................................................. 158 
Appendix E  -  Minimum Two-Party E-Receipt JSON Schema (v1.x) ..................................... 162 
Appendix F  -  Roster-to-Claim Cross-Check Rules .................................................................. 166 
Appendix G  -  Sanctions, Reasons & Weighing (R&W), Contradiction Matrix, and 
Independent-Reasoning Certificate (IRC) .................................................................................. 169 
Appendix H  -  Reasons & Weighting (R&W) ............................................................................ 173 
Appendix I  -  Contradiction Matrix ........................................................................................... 178 
Appendix J  -  Independent-Reasoning Certificate (IRC) ......................................................... 181 
Appendix K  -  Accessible Plan Pack (Plain English + Easy Read) .......................................... 185 
Appendix L  -  Weekly Community Schedule & Presence/Participation Tracker .................. 188 
Appendix N  -  Interpreter/Auslan/AAC Toolkit ....................................................................... 195 
Appendix O  -  First Nations Partnership MOU Template & Cultural Plan .......................... 198 
Appendix P  -  Rural Micro-Hub Operating Pack & Tele-OSCE Protocol ............................. 203 
Appendix Q  -  IDC Curriculum Map, EPA Logbook & OSCE Rubrics ................................ 207 
Appendix R  -  Privacy, DPIA & Feed Registry ......................................................................... 214 
Appendix S  -  Dashboard Tiles, Suppression & Publication .................................................... 218 
Appendix T  -  Audit Log Specification ....................................................................................... 222 
Appendix U  -  Red-Team Scenarios & Reports ......................................................................... 227 
Appendix V  -  Peer Calibration Rubrics & Quality Summary Template ............................... 231 
Appendix W  -  Evaluation Access Protocol................................................................................ 235 
Appendix X  -  ROI Workbook Notes & Assumptions Register ............................................... 239 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 11 
 
Appendix Y  -  Owner Matrix & Escalation Playbook .............................................................. 243 
Appendix Z  -  Practice-Note Crosswalks (including “Thriving Kids”) ................................... 246 
Appendix AA  -  Service Template & Crosswalks Library (download pack index) ............... 254 
Crosswalks  -   the double A baseline standards............................................................................ 254 
Templates  -  grouped by Appendix ................................................................................................ 255 
Appendix AB  -  Pharmacy Psychotropic Stewardship Protocol .............................................. 264 
Appendix AC  -  Dental Desensitisation Protocol ....................................................................... 269 
Appendix AD  -  “Quiet Hours” Community MOU Template.................................................. 273 
Appendix AE  -  Transport Staff Pocket Card ........................................................................... 276 
Appendix AF  -  Assistive Technology (AT) & AAC Procurement Spec ................................. 279 
Appendix AG  -  Tribunal/OPA/DSC “Candour by Template” Exemplars ............................ 284 
Appendix AH  -  Fiduciary Safeguards & Financial Safety Pack ............................................. 288 
Appendix AI  -  Industrial Relations & Insurance Brief Templates......................................... 292 
Appendix AJ  -  Research & Evaluation Partnership MoU ...................................................... 297 
Appendix AK  -  Operational Prompt Pack ................................................................................ 300 
Appendix AL  -  Publication & Dashboard Schema (Public, Family, Provider) ..................... 306 
Appendix AM  -  Public Narrative & Media Plan ...................................................................... 311 
Appendix AN  -  Police Academy Integration Plan (Cognitive Disability Capability) ........... 315 
Appendix AO  -  IDC Equivalency & Bridging Matrix ............................................................. 319 
Appendix AO.1  -  DSC Equivalency & Bridging Matrix ......................................................... 330 
Appendix AO.2  -  Tribunal Practice Note (Brief): Two-Key Guardianship .......................... 334 
Appendix AO.3  -  RPL Evidence Checklist (Recognition of Prior Learning) ........................ 338 
Appendix AP  -  Two-Key Guardianship (specific) .................................................................... 341 
Appendix AQ  -  OPA/OPG Investigations Code Addendum: Two-Key Guardianship ........ 347 
Appendix AR  -  Procurement Direction & Independent Pairing Pool (IPP) Service-Level 
Agreement ...................................................................................................................................... 351 
Appendix AS  -  Dashboard Tile Specifications: Two-Key Guardianship ............................... 353 
Appendix AT  -  Talking Points & Q&A: Two-Key Guardianship .......................................... 355 
Appendix AU  -  Bibliography ...................................................................................................... 357 
Glossary & Acronyms ................................................................................................................... 359 
Acknowledgements & References ................................................................................................ 370 
Stewardship, Data Publication & Author Exit (governance declaration) ............................... 377 
Afterword  -  Language, visibility, and what comes next .......................................................... 379 
Appendix AZ  -  Legal, Risk & Publication Basis ...................................................................... 388 
 
 
 

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Foreword 
 
Seeing the Unseen: Framing for Professionals, Families, Frontline and the Person at the 
Centre 
For some people with a cognitive disability, daily life is lived in landscapes few of us can see. 
What may look like coping, routine, or “getting by” can mask a very different interior: 
confusion, dislocation, or a sense that what others experience is continuously/completely 
foreign. For some, there is no clear grasp of what is happening to them or to those around 
them - only fragments of awareness and shifting signals that are hard to interpret. 
For some people with a cognitive disability, the challenge isn’t only what is happening but 
when. Life can arrive a half-second late and out of order - like subtitles that don’t match the 
film. Words are heard, but the meaning lands after the moment has already moved on. By the 
time a reply is shaped, the topic has shifted and the social penalty has begun. What looks like 
silence or indifference is often a race against latency. 
The world also assumes a shared map. For some, the map redraws itself mid-journey: signals 
swap places, rules change without warning, background noise becomes foreground threat. 
Ordinary tasks carry a translation tax - decoding tone, filtering glare, sorting competing 
instructions - before the task itself even starts. Energy is spent on keeping up, not on moving 
forward. The person you see in the afternoon may be running on the last, thinnest thread 
because the morning’s “simple” interactions have already charged full fare. 
Much of the work is invisible. Many people learn to mask and cope in ways only they can - 
copying cues, laughing a beat late, rehearsing stock phrases - so others feel comfortable. The 
cost of that masking is misread as “behaviour” when it fails, rather than as a debt finally 
called in. Memory can be like chalk on wet pavement: present, then gone; effortful to hold; 
easy to smudge. Precision is possible, but it sometimes needs time, stable cues and one thread 
at a time. 
This is the difference most people never see: not a lack of care or capacity, but a constant 
mismatch between the world’s speed and the person’s processing. When we slow the clock, 
make meaning visible, and keep the ground rules still for long enough, the person’s world 
lines up with ours - and the distance many mistake for disinterest reveals itself as exceptional 
endurance. 
 
This level of aloneness does not stop with the individual. Those closest - parents, guardians, 
siblings, volunteers, support workers - often stand at the edge of that same terrain. They too 
can feel outside the circle, watching someone they love or support navigate realities that do 
not fully align with their own. The disconnect is shared, though differently: the ache of 
wanting to understand more, to translate more, to make belonging possible, and meeting the 
limits of language, systems, or patience. 
Most of society does not see this deeper level. They see services delivered, programs 
completed, or behaviours managed, without recognising the constant work of those who are 

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both present and yet placed on the outer. They do not see the quiet exhaustion of mothers and 
fathers, guardians who become accidental experts, learning the language of medical reports, 
behavioural plans, and tribunal hearings while holding together the daily rhythms of family 
life. They do not see the frontline worker who holds calm through a storm, steadying their 
own emotions while absorbing the weight of another’s distress, often without the resources or 
recognition the role deserves. They do not see the sibling who both loves and worries - who 
helps with care, adapts their own childhood or adulthood around another’s needs, and quietly 
carries the question of future responsibility. 
They do not see the sleepless nights where parents/ guardians replay the day’s events, 
wondering if they made the right decision; the hours waiting in clinics or on hold; the 
repeated telling of the same story to yet another professional who may or may not listen. 
They do not see careers, friendships, and personal ambitions traded away for constancy in 
care. They do not see the volunteers who show up again and again, binding their purpose to 
the fragile threads of another’s progress, often unnoticed by the broader community. This 
work - intimate, unrelenting, and rarely celebrated - sustains lives that might otherwise fall 
through the cracks. It is the unseen backbone of the cognitive-disability sector, carried not by 
systems alone but by the daily presence of those who refuse to step away, even when their 
own sense of belonging is strained and their own needs are pushed to the margins. 
Most of society also does not experience the gaps in legislation, the obstacles policymakers 
must negotiate, or the frustrations of those in hierarchical roles who are trying to make 
change. They do not see long hours spent drafting reforms only to have them delayed; 
compromises forced by budgets and competing priorities; quiet battles with outdated rules; 
the lobbying and pressure that bend decisions away from lived reality. They do not see the 
tension of responsibility for systems that are under-resourced, fragmented, and politicised; 
the weight carried by tribunal members making decisions with imperfect information; or the 
fatigue of senior managers who know the gap between policy intent and frontline practice but 
lack the levers to close it. Just as families and frontline workers stand on the outer in their 
own way, legislators, advocates, and administrators can feel on the outer within their own 
systems - caught between aspiration and reality. Their efforts, too, often go unseen, dismissed 
as bureaucracy rather than understood as attempts to inch forward a system never designed 
for such complexity. 
Beneath these disconnections lives something rarely named but always there: invisible hope. 
It does not rise from easy victories but from the strength it takes to keep moving - to try 
again, to show up again, to love again in ways that may never be fully understood or repaid. 
Those who live this daily aloneness model a kind of courage most of us will never have to 
find in ourselves. If we learn to see that courage clearly - not as deficit but as deep resilience - 
we can draw upon it. It can teach us how to shape better systems and better living, where no 
one’s interior world is written off as unreachable and where those who carry the weight of 
care are welcomed into the centre. 
You, reader, are the gift. You are the treasure.  
This paper is a call to courage and to responsibility: a reminder that what you have lived - the 
pain and the joy, the confusion and the clarity - can be turned outward as service that makes a 
difference. In doing so, you remind others they are not alone, and you help shape a more 
human world for all of us. Take a moment to recognise that - not in an egotistical way, but in 
truth. Many of us were raised to downplay our strengths. Yet to support, advocate, and care, 

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we must see clearly what we bring. Compassion, resilience, patience, determination, 
knowledge, skill: these are not small things. They shape lives. They let us stand between two 
worlds - the inner life of the person we love or support and the wider society that does not 
always know how to listen. 
Across Australia, too many people with cognitive disability still live behind closed doors, 
their days shaped by thin training, weak supervision and paperwork that stands in for life. In 
the worst cases, avoidable hospitalisations and preventable deaths have occurred. A small 
number exploit gaps in the system; far more are simply under-prepared and under-supported. 
Either way, quality of life is reduced, trust eroded, risk amplified. This white paper is written 
to change that now, not someday. 
It stands on the foundation of the Disability Royal Commission. The Commission set the 
direction for an inclusive Australia and produced a comprehensive reform blueprint. Our task 
is narrower and more immediate: to translate that direction into minimum operational 
standards that services, systems and professions can adopt now. This is additive, not 
adversarial: the Commission set the compass; this paper lays the track and signals, so people 
experience promised change in ordinary places, at ordinary times, with ordinary rights intact. 
We include Acquired Brain Injury because the realities of ABI - fluctuating capacity, 
cognitive-communication barriers, executive-function and sensory changes, fatigue, mood 
and behavioural impacts, mealtime and swallow risks, seizure vulnerability, and episodic 
health and justice contact - intersect heavily with intellectual-disability services, tribunals, 
and emergency systems. Integrating ABI avoids duplicate systems, honours person-first 
practice, and delivers one coherent standard across ID and ABI with role clarity, observed 
competence, and transparent results. 
This is a design-and-implementation tool, not a brochure. It weaves policy, economics, 
clinical governance, market design, behavioural science, data and AI, law, anthropology and 
ethics into a practical playbook. Every claim is paired with a method or measure readers can 
verify, adapt and improve. Where an ask for higher standards exists, examples also supply the 
means. 
A few core shifts signal the way forward. First, safety and dignity are the floor, not the 
ceiling: least-restrictive practice by default, with structured learning reviews after any 
restraint or sedation. Second, scope is earned by observed competence, not by title: 
preparation, supervised practice and renewal become the norm. Third, truth is restored by 
design: simple integrity tools make the truthful thing the easy thing and the dishonest thing 
hard to get away with. Fourth, presence in public becomes standard again: roles, routines and 
access that place people in ordinary places where life is lived - workplaces, clubs, libraries, 
faith gatherings, parks, markets - because communities get better at being communities when 
everyone is visible within them. 
A word to parents, families, guardians and volunteers. It can be confronting to accept that a 
loved one has a cognitive disability. Familiar responses - over-protection, constant worry, 
taking over because it’s quicker - are human, but they can lead to dependency and a reduced 
life. There is no handbook, and many are left to their own devices, guided by handed-down 
advice that was “satisfactory” - but was it? Our role is to love, embrace difference, nurture 
growth, set routines for healthy diet, movement and connection, and - most importantly - to 
recognise we will one day not be there. Our duty is to foster healthy independence that 

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outlives us. Nothing is “wrong” with who this person is. What is wrong is when we limit who 
they are to our fear or convenience. Offer real choices, ordinary places, and time to practise, 
and people grow. Take over, and lives shrink. Choose dignity of risk today: one choice 
offered, one ordinary place visited, one task done by them - not for them. They can adapt. We 
must meet them there. Starting now. 
“I will see the person first. I will not make them my shadow because it’s faster. I will offer 
real choices and time to practise in ordinary places. I will trade fear for best practice, rescue 
for coaching, control for dignity of risk. They can adapt. I can adapt. We will do this 
together.” 
This Standards Refresh is not a return to institutions, nor a continuing of the silent ebb into 
micro-institutions. It lifts the floor where life is lived - homes, streets, schools, clinics and 
courts. It hard-wires honesty into money and data, publishes what matters, and pauses scale 
when reality diverges from plan. Many people of position have climbed ladders without ever 
being taught this domain; the remedy is learning plus proof, not blame - and proof for 
everyone, including those who set policy, audit practice or decide rights. The work is 
difficult. It should be. Lives, dignity and futures depend on it. 
If we walk together - people and families, workers and providers, tribunals and advocates, 
funders and governments - we can build a protopia: better each year. A society where people 
with cognitive disability are present, known and thriving, and where those who stand with 
them are recognised as the professionals they become - because they proved it. 
The responsibility can be heavy; it can isolate; it can exhaust. It also carries the possibility of 
something extraordinary: to make meaning where none was offered, to ensure dignity where 
it was overlooked, and to create connection where silence might otherwise prevail. Invisible 
hope lives here. It is not loud or easy. It does not erase daily challenges. It persists in each 
small act of showing up again; in choosing to believe that a life on the margins deserves 
centre ground; in building bridges where words fall short. This paper is offered in that spirit - 
toward a society where no one is left unseen or unheard. 
 
This Foreword is a commitment in plain language; the pages that follow set out the changes, 
guardrails and timelines to make it real. 
 
 
 
 
 
 
 
Reader’s note (on difficulty & good faith) 
If parts of this paper feel on-point or off-base, either way it signals work to do - improve our systems or improve this 
paper. When the material feels heavy or dense, pause and return to the Foreword (or the Afterword). They’re built to 
reset bearings: why this exists, who it’s for, and how to use it next. Please test the ideas, correct them where needed, 
and carry the work forward. 
 

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Salute to the Disability Royal Commission  -  and how this 
paper operationalises it 
This paper stands in respect of the Commission’s truth-telling and reform intent. Its 
contribution is operational: enforceable standards, time-bound reviews, field-tested tooling 
and publication rules that translate principle into daily practice. Two-Key Guardianship (no 
one decides alone) is the keystone that lets the rest work at pace and with safety.  
Concretely, it: 
• Stops unilateral, high-impact decisions by requiring two independent keys (or MPG 
quorum) for life-shaping calls, with a Tier-0 emergency pathway that acts fast and 
then reviews within 72 hours with a fade plan. 
• Makes least-restrictive measurable via a restraint hierarchy, time-keeping, and 72-
hour learning reviews tied to the Two-Key rule. 
• Professionalises the frontline (IDC) with mapped curriculum, observed practice 
(OSCEs) and renewal - so the quality of each “key” is visible and improvable. 
• Embeds truth-by-design (two-party e-receipts; roster-to-claim cross-checks; 
proportionate sanctions ladder) so integrity is built-in, not bolted on. 
• Adds independent verification (DSC) and structured reasoning tools (Reasons & 
Weighings; Contradiction Matrix) that, together with Two-Key, yield appeal-ready 
records by default. 
• Separates coordination from provision and normalises switching, reducing conflicts 
and strengthening the independence of keys. 
• Publishes progress through privacy-safe dashboards, including Two-Key tiles 
(coverage, emergency use, reviews completed in 72h, time to second key). 
• Secures rural parity with micro-hubs, tele-co-sign/tele-OSCEs and scholarships so 
Two-Key is practical outside metros. 
[Cross-refs: Shared Decision Standard - Two-Key; Safety & Restrictive Practices 
Standard; Workforce Standard - IDC; Truth-by-Design Standard; Independent 
Verification Standard; Service Model Standards (life in community); Data, 
Dashboards and Privacy.] 
Design constraints  -  and how the standards meet them 
• Decision speed and safeguards. Two-Key uses an Independent Pairing Pool (IPP) 
with clear SLAs (urgent 2h/24h; standard 2bd/10bd) and a Tier-0 emergency path 
with mandatory 72-hour review - so speed never trades off safety. [See Appx AR (IPP 
SLA); Appx AS (Two-Key tiles).] 
• Equity and rural parity. Micro-hubs, tele-co-sign, tele-OSCEs, scholarships and 
practical travel supports keep regions viable. 
• Linguistic and cultural access. First Nations partnership, CALD/Auslan access, 
Plain English and Easy Read artefacts; cultural-fit pairing for the second key. 
• Privacy and safety. DPIAs for all flows; role-based access; suppression rules; 
immutable audit logs. 
• Interoperability and cost. Minimum open schemas; leverage existing systems; 
phased “switch-on” to avoid big-bang risk. 

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• Time-to-value. Pilot → verify → publish → scale, with go/no-go gates tied to QA 
and privacy conformance. 
Where awareness breaks down today  -  and how this paper closes it 
The Royal Commission revealed critical gaps in awareness and practice across the disability 
ecosystem - gaps that leave people with cognitive disability vulnerable to systemic failings. 
These gaps appear at multiple layers, including but not limited to: 
• External review and oversight: Administrative Review Tribunal (ART); Federal 
Court (judicial review of ART/NDIA decisions); NDIS Quality & Safeguards 
Commission (Commissioner / Compliance & Enforcement); Public Guardian / 
Administrator (State Trustees). 
• NDIA decision and planning chain: NDIA CEO/Delegates (legal plan/funding 
decisions); NDIA Planners; Participant Support Officers (PSO); LAC / Early 
Childhood Partners (PITC); Regional/State/Executive Directors. 
• Provider management and clinical governance: Service/Operations Managers; 
Practice/Clinical Leads; Team Leaders; Behaviour Support Practitioners 
(Provisional/Core/Advanced); Senior Allied Health; Allied Health clinicians; Clinical 
Directors/Principal Clinicians. 
• Coordination and adjacent roles: Specialist Support Coordinators (Level 3), 
Senior/Lead Support Coordinators, Support Coordinators (Level 2), Support 
Connection (Level 1), Psychosocial Recovery Coaches, Plan Managers, ILO 
Designers/Facilitators, Justice/Hospital/Housing Liaisons, Community 
Connectors/Cultural Liaisons/Auslan Interpreters, Disability/Appeals Advocates. 
• Operational and entry roles: Senior Case Managers/Care Coordinators (legacy), 
Case Managers/Care Coordinators, Intake Coordinators/Service Navigators/Care 
Finders, Roster Coordinators/Schedulers, Support Coordinator Assistants/Team 
Admin. 
• Frontline workforce and natural supports: Direct Care/Disability Support 
Workers/Residential Support Workers/Mentors; Trainee/Entry-level workers; parents, 
guardians and volunteers. 
What this paper does in response: 
• Traceability by design. Each design choice in these standards directly answers a 
documented DRC risk or failure mode. 
o Two-Key Guardianship + IPP → ends single-actor decision risk; preserves 
urgency with Tier-0 + 72-hour review; creates a verifiable trail (independence 
screen; pairing timestamps). 
o IDC pathway → lifts capability and candour through observed practice, 
OSCEs and renewal - raising the calibre of each key across roles and settings. 
o Restraint hierarchy + 72-hour reviews → converts incidents into learning 
with fade plans and measured reduction. 
o Two-party e-receipts + roster-to-claim cross-checks → shifts integrity from 
after-the-fact to built-in. 
o DSC + Reasons & Weighings + Contradiction Matrix → improves 
transparency in contested matters and supports appeal-ready publication. 
o Independent coordination + easy switching → reduces conflicts and 
empowers families. 

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o Dashboards + open schemas + DPIAs → enable public accountability 
without exposing personal data; Two-Key metrics include coverage, 
emergency rate, 72h review compliance, and median time to second key. 
o Phased implementation with micro-hubs → matches capacity to demand 
and protects rural access. 
o ROI workbook + publication cadence → aligns finance with outcomes and 
signals market quality. 
 
Invitation to the field. This white paper is a well-reasoned, well-researched proposal - and a 
catalyst. The paper invites ART, courts, the NDIS Commission, public 
guardians/administrators, NDIA roles (CEO to PSO), partners (LAC/EC), provider 
executives and clinical leaders, coordinators, plan managers, advocates, frontline workers, 
families and volunteers to use it as the basis for green-paper processes or collaborative 
refinement. The aim is shared: fewer blind spots, faster learning, and visible safety. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 20 
 
What this paper is (status and how to use it) 
The Standards Refresh outlined here is already before decision-makers. The core source set  -  
A_DSC_IDC_Reform_Blueprint.pdf, 
B_DSC_IDC_Policy_and_Legislative_Pack.pdf, 
C_Audit_Information_Pack_Guardianship_OPA_Investigations.pdf, 
D_IMPLEMENTATION_ORDER.pdf, and 
E_DSC_IDC_Two-Key_Guardianship_Pack.pdf  -  
has been provided to Attorneys-General of Australia and Ministers in every jurisdiction, and 
to the responsible Commonwealth offices. These documents contain the legal, policy and 
operational blueprint instruments needed to begin. This paper explains, in plain terms, why 
those instruments sit with those who can change failing systems, and how to switch them on 
without waiting for slow, omnibus legislation. 
This design-and-implementation tool ensures every claim is paired with a template, method 
or measure so readers can verify, adapt and improve. URLs and graphs are presented in plain 
text so the document stays copy-and-paste clean while remaining interactive. Where the 
paper asks for higher standards, it also supplies the means: checklists, forms, calculators, 
dashboards and a cost-benefit workbook. Where it misses the mark, you  -  the reader  -  
contribute to make it better. 
A walk-with Standards Refresh (not a push) 
“Push” invites resistance. This is a walk-with change: participants and families as narrators of 
evolving times; providers as co-design partners; tribunals and public advocates as guarantors 
of candour; funders and auditors as stewards of truth-by-design; governments as conveners 
who remove blockers and align incentives. Same standard, different pathways. 
Australia’s geography demands a design that still works when roads flood, planes are 
grounded and signals drop. We hold one national standard for safety and competence, 
delivered through IDC/DSC/Two-Key micro-hubs, mobile clinics, tele-OSCEs, quarterly 
satellite assessment hubs and offline-first integrity tools  -  so rural and remote communities 
receive the same quality without compromise. The progression succeeds only as 
collaboration, shoulder to shoulder. 
 
Four new primary standards, refresh and clear the pathway ahead: 
 
• From “Direct Care” to a Profession  -  what changes, what carries through 
 
• Coordination, Adjacent, and Operational Licence Classes  -  meet or bridge to the 
standard 
 
• Closing the reality gap  -  judiciary & oversight with DSC as the live bridge 
 
• Future-proofing with a simple failsafe: Two-Key Guardianship (no one decides 
alone). 
 

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From “Direct Care” to a Profession  -  what changes, what carries through 
 
First, name what “Direct Care” has been 
When this paper states “Direct Care”, it is explicitly referring to the roles currently housed 
under that umbrella: 
• Direct Care Worker (DC) / Disability Support Worker (DSW) / Support Worker / 
Residential Support Worker / Mentor  -  Frontline 
• Trainee / Support Worker (Entry-Level)  -  Frontline 
These titles have carried the day-to-day weight of the system. The issue is not the people; it’s 
the label and lax scaffolding around the work. 
The central change: retire the label, professionalise the coalface 
Today, those titles can be the doorway to life-shaping acts without proof of observed 
competence in ID/ABI and associated cognitive disability fields of practice. Over time, a 
“fill-the-shift” economy emerged: thin training, inconsistent supervision, and scope-creep 
into safety-critical tasks. That operating model ends here.  
We retire the “Direct Care” label and replace the stream with an Integrated Disability 
Clinician (IDC) pathway that makes competence, supervision and re-validation visible. 
Integrated Disability Clinician (IDC)  -  the new baseline (runnable rules) 
• Title protection & pathway. The roles listed above transition into IDC Bands 1-3 with 
protected titles and mapped scope. No one works unsupervised on safety-critical tasks 
without the corresponding observed sign-off (OSCE/ EPA). 
• Minimum entry standard. No entry point sits below two years of mapped study (or a 
formally assessed equivalency/RPL). That is the basement, not the ceiling. 
• Observed competence (not paper promises). Mandatory OSCEs cover: mealtime 
safety/dysphagia; seizure response (incl. rescue-med delegation where lawful); 
medication safety; communication & AAC in conversation; Positive Behaviour 
Support fidelity; least-restrictive practice; documentation integrity. 
• Supervision you can see. Named supervisor with ratio caps; scheduled field 
observation; 72-hour learning reviews after Tier-0 events; and an outcome-weighted 
re-validation cycle. 
• Clear scope boundaries. Safety-critical acts (restraint, PRN psychotropics, 
guardianship-sensitive decisions) require Two-Key and documented Reasons & 
Weighings - never a single actor. 
• Public accountability. Publication tiles (Appendix S) expose competence coverage, 
supervision adherence, OSCE pass rates, restraint minutes and time-to-decision. 
Transition map (so people aren’t lost in the upgrade) 
Appendix AO-1…AO-3: Equivalency, Bridging Plans, RPL evidence. 

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• AO-1 Equivalency Matrix. Maps each current “Direct Care” title (DC/DSW/Support 
Worker/Residential Support Worker/Mentor/Trainee) to the appropriate IDC Band 
with provisional scope. 
• AO-2 Individual Bridging Plan. Sets the shortest, safe path to full IDC sign-off 
(modules, supervised hours, OSCEs, cultural safety/AAC). 
• AO-3 RPL Evidence Checklist. Credits prior learning and competence fairly (work 
logs, supervision notes, incident reflections, family feedback). 
• Time-boxed uplift. Typical bridging window 6-18 months depending on evidence; 
paid study time and micro-credential blocks to avoid income shock. 
• Grandparenting with guardrails. Incumbents keep working within clearly bounded 
scope while they bridge; safety-critical tasks require paired sign-off until OSCEs are 
passed. 
• Title sunset. “Direct Care/DSW/Support Worker/Residential Support 
Worker/Mentor/Trainee” sunset as public-facing titles at the end of the transition 
window; internal HR may retain legacy codes for payroll only. 
• Appendix S: dashboard tiles & suppression rules. 
What ends vs what stays (plain) 
• Ends: shift-filling as a competency proxy; solo decisions on consequential matters; 
informal medication/PRN practices; undocumented use of restraint; opaque 
supervision. 
• Stays (and strengthens): the human core of the work - relationship, daily living 
support, dignity of risk, cultural humility - now backed by demonstrated proficiency, 
routine coaching, and publication-grade records. 
Coordination, Adjacent, and Operational Licence Classes  -  meet or bridge to the 
standard 
Scope of this clause. The following titles are in scope for uplift and licensing under this 
paper. Titles are grouped to make responsibilities, supervision, and independence-from-
provision explicit. 
1) Coordination & Adjacent Roles (licence class: COORD) 
Navigator stream (ranked, highest → lowest) 
• Navigator  -  Tier 3 (Specialist) (legacy: Specialist Support Coordinator L3) 
• Navigator  -  Senior / Lead (legacy: Senior / Lead Support Coordinator) 
• Navigator  -  Tier 2 (Coordination) (legacy: Support Coordinator L2) 
• Navigator  -  Tier 1 (Setup & Linkage) (legacy: Support Connection L1) 
Adjacent functions (parallel to Navigator  -  not rank-ordered) 
• Psychosocial Recovery Coach (parallel, MH-focused) 
• Behaviour Support Practitioner (clinical PBS; distinct clinical stream) 
• Plan Manager (financial intermediary) 
• ILO Designer / Facilitator (Individualised Living Options) 
• Justice / Hospital / Housing Liaison (incl. Discharge Planner) 
• Community Connector / Cultural Liaison / Auslan Interpreter 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 23 
 
• Disability Advocate / Appeals Advocate 
Core guardrails (COORD): 
• Separation of coordination from provision (no direct financial interest in funded 
supports being coordinated). 
• Two-Key interface for consequential decisions they influence (moves to/from 
SDA/SIL; psychotropic initiation/continuation; restrictive-practice authorisations): 
must log Reasons & Weighings (R&W) and second-key details. 
• Navigator compatibility. Where Navigators are stood up, COORD licence maps to the 
Navigator ⇄ IDC handshake with warm handover obligations. 
• Observed practice. OSCE/EPA for: conflict-of-interest screening; R&W drafting; 
plain-English explanations; cultural safety and interpreter/AAC use; escalation to 
DSC; evidence-based referral. 
2) Operational & Entry Roles (licence class: OPS) 
Multi-site / organisational ops (ranked, highest → lowest) 
• Regional / State Manager (portfolio leadership) 
• Operations Manager / Service Manager (multi-site) 
• Practice Manager / Clinical Lead (quality & safeguards across sites) 
• Quality & Safeguards / Compliance Manager (incidents, audits, standards) 
• Workforce / Rostering Manager (coverage, fatigue, continuity) 
• After-hours Duty Manager / On-Call (escalations) 
Site & small-cluster ops  -  SIL / group homes (ranked) 
• Service Manager (site or small cluster) / SIL Service Manager 
• House Manager / Site Manager / House Supervisor (often “SIL House Manager”) 
• Senior Support Worker / Team Leader 
• Disability Support Worker (DSW) / Direct Care Worker (DC) / Support Worker 
Front-door & admin (ranked) 
• Senior Case Manager / Care Coordinator (legacy → map to Navigator - Senior/Lead 
where appropriate) 
• Case Manager / Care Coordinator (legacy → map to Navigator - Tier 2 where 
appropriate) 
• Intake Coordinator / Service Navigator / Care Finder (legacy title set → remains 
OPS; interfaces to Navigator - Intake) 
• Roster Coordinator / Scheduler 
• Support Coordinator Assistant / Team Admin 
Core guardrails (OPS): 
• No scope creep into safety-critical decisions. OPS roles cannot authorise or co-sign 
restrictive practices, PRN psychotropics, or accommodation moves. 
• Gateway integrity. Intake/Navigation functions require OSCE for eligibility triage, 
warm handover, and e-receipt issuance. 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 24 
 
• Records you can publish. OPS must produce publication-ready artefacts (plain-
English notes; time-stamped handovers; role-based visibility). 
Licence requirements  -  show equivalency or bridge 
All roles above (COORD, OPS), and the previously listed Behaviour Support Practitioner, 
SIL/Service Manager, House/Site Manager, Practice Manager, Quality & Safeguards 
Manager are required to either: 
1. Demonstrate rigorous equivalency to the new standard 
o Mapped knowledge checks (legislation, least-restrictive, Two-Key, R&W, 
privacy/DPIA, cultural safety, interpreter/AAC). 
o Observed practice (OSCE/EPA) for role-specific tasks (see lists above). 
o Portfolio evidence (de-identified artefacts: plans, handovers, R&W notes, 
escalation records, calibration memos). 
or 
2. Complete gap training + supervised practice 
o Individual AO-2 Bridging Plan with modules, supervised hours, and OSCE 
dates. 
o Time-boxed (typical 6-12 months COORD; 3-9 months OPS), with protected 
study time. 
o Provisional scope during bridging; safety-critical gates are non-negotiable (no 
co-signing until OSCE pass). 
Titles alone do not preserve scope. Transitional, time-limited RPL is offered to avoid 
disruption; public-facing titles are retained only where licence & OSCE are current. 
Independence, supervision, and conflicts 
• Independence from provision (COORD). Financial or managerial links to the provider 
being coordinated require declared conflict, DSC note, and alternate second key. 
Persistent conflict → switching is normalised. 
• Supervision ratios. Named supervisor with case-complexity caps; 72-hour learning 
reviews after Tier-0 events; quarterly DSC calibration (file-vs-field). 
• Cultural safety. First Nations partnership, CALD/Auslan access; cultural-fit pairing 
for the second key; interpreter/AAC triggers are mandatory. 
Sanctions & sunset 
• Non-compliance ladder: improvement plan → conditions on licence → suspension → 
de-registration (published). 
• Title sunset: legacy public titles that mask scope or independence (e.g., generic “Case 
Manager” used for coordination + provision) must migrate to COORD or OPS with 
explicit scope lines by the end of the bridging window. 
 
 
 
 
 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 25 
 
Closing the reality gap  -  judiciary & oversight with DSC as the live bridge 
 
Title housekeeping (who’s in scope). 
This clause covers two groupings whose decisions shape daily practice: 
A. External review & oversight (EO): 
• Administrative Review Tribunal (ART) - external merits review (members/registrars) 
• Federal Court - judicial review of ART/NDIA decisions 
• NDIS Quality & Safeguards Commission - Commissioner; Compliance & 
Enforcement 
• Public Guardian / Administrator (incl. State Trustees; OPA/OPG/NSWTG variants) 
• Ombudsman (jurisdictional) 
B. NDIA decision & planning chain (NDIA): 
• NDIA CEO / Delegates - legal plan/funding decisions 
• NDIA Planners - plan preparation/variation (for delegate approval) 
• Participant Support Officers (PSO) - case administration 
• Partners in the Community (PITC) - LAC / Early Childhood Partners 
• Regional / State / Executive Directors - operational leadership 
Problem statement  -  why top-down must cut through 
Oversight often lags the coalface. Evidence from audits, coronial findings, lived-experience 
testimony, incident reviews and frontline exit interviews shows a widening gap between what 
happens in homes, day programs and emergency settings, and what reaches tribunal 
members, OPA/OPG investigators, the Ombudsman, and NDIA delegates. Paper files are 
retrospective and curated; live practice is dynamic and uneven. Critically, those in higher 
positions are fed - and too often must rely on - information produced by those beneath them. 
When that information is inaccurate or selectively framed - and is then inadvertently 
condoned via desk reviews and cycling templates - nothing changes. Decisions anchored to 
titles, averages and assurances (rather than observed competence and live field signals) allow 
restraint to drift from “last resort” to routine, assume documentation integrity, and misread 
risk. A direct refresh of knowledge at the top - bypassing the usual information chain when 
needed - is not a slight on the workforce; it is a safety function. The DSC bridge, Two-Key 
verification, and file-vs-field calibration are the mechanisms that make that cut-through 
routine, auditable and fair. 
The Decision Support Consultant (DSC)  -  neutral, time-bound, field-verified 
Who appoints. The tribunal/ART, Public Guardian/OPA/OPG, Ombudsman or NDIA 
delegate appoints the DSC from a conflict-screened panel; never by the provider. 
What they do. The DSC tests file ⇄ field and returns verifiable signals EO/NDIA can rely on 
- usable in reasons, orders and sanctions. 
Verification domains (minimum): 
• Equivalency & scope verification. OSCE/EPA pass logs; re-validation dates; 
supervision notes; shadowed observations for Support Coordination (all levels), 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 26 
 
Psychosocial Recovery Coaching, Plan Management, ILO design/facilitation, 
Justice/Hospital/Housing liaison, and for clinical/ops leads (e.g., BSPs, House/SIL 
Coordinators, Practice Managers). Scope is earned by competence, not conferred by 
title. 
• Integrity signals. Two-party e-receipts; documentation-integrity scores; roster↔claim 
reconciliations; Reasons & Weighings and the Contradiction Matrix to surface and 
resolve conflicts of evidence. 
• Restraint & crisis review. Automatic 72-hour learning reviews after any 
restraint/sedation; verification of mealtime/IDDSI, seizure protocols and medication 
reconciliation so EDs/wards never “start from zero”. 
• Calibration protocol. Quarterly double-blind file-vs-field reviews and scheduled 
shadowing days, so tribunals/guardians/ombudsmen see practice in situ, not only on 
paper. 
Access & powers (process-safe): 
• Role-based access (least-privilege); DPIA logged; person/family consent sought 
where required; cultural safety triggers (First Nations/CALD/Auslan). 
• Right to request contemporaneous materials (shift notes, rosters, MARs, BSP plans, 
CCTV where lawful), conduct interviews, and observe practice. 
• Ability to recommend Two-Key invocation or escalation to sanctions ladder where 
risk is immediate. 
Safeguards. DSCs are panel-appointed, conflict-screened, subject-led in method, and report 
with published methodology (not opinion). Findings feed licensing/scope decisions and 
public dashboards, lifting the market toward observed competence, transparent integrity and 
least-restrictive practice. 
Outputs the decision-makers can use (lay technical twin) 
Every DSC report ships with a Plain-English summary (for the person/family) and a technical 
annex (for EO/NDIA): 
1. Scope & Competence Table  -  who is licensed to do what, next renewal due, gaps 
outstanding. 
2. Integrity Pack  -  e-receipt coverage, roster↔claim anomalies, documentation-
integrity score, unresolved contradictions. 
3. Safety Pack  -  restraint minutes by type, 72-hour review completion, mealtime/IDDSI 
and seizure protocol conformance, medication reconciliation status. 
4. Reasons Twin  -  a ready-to-attach Right-to-Reasons draft for EO/NDIA 
decisions/orders. 
5. Fade & Switching Plan  -  least-restrictive trajectory, provider/key switching where 
conflicts persist. 
Order & decision templates (how EO/NDIA act on the signals) 
• Tribunal/ART order add-ons. “Two-Key required for [decision domain]; DSC re-
check in 90 days; publish tiles S-## with suppression.” 
• Public Guardian directions. “Appoint alternate second key due to conflict; restrict 
scope until OSCE passed; schedule calibration visit.” 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 27 
 
• NDIA delegate directions. “Navigator/COORD warm handover required; plan 
condition: e-receipt  roster↔claim cross-checks; review in 60 days.” 
• Ombudsman resolution. “Undertaking: implement publication tiles; independent DSC 
audit; apology  lay reasons to person/family.” 
Future-proofing with a simple failsafe: Two-Key Guardianship (no one decides alone).  
Too many consequential decisions about a person’s life, liberty, health, home, money or 
relationships are still made by one tired mind, often behind a closed door and under time 
pressure. Two-Key Guardianship is a humility rule as much as a safeguard. It asks us to pause 
long enough to bring in a second, independent mind - and to place the person’s will and 
preferences at the centre - before we change something that cannot easily be undone. 
In practice it is human and light-touch: two independent co-signers (or a small quorum where 
that is ordered) confirm the decision, write a short plain-English reason, and record the 
person’s wishes in their own words (with supported decision-making where needed). In an 
emergency we act to make the person safe first, then we explain and review within 72 hours 
so temporary measures do not become a quiet default. When facts are contested, an 
independent verifier checks file-versus-field so decisions stand up to daylight. Rural and 
regional families are not left behind: pairing can happen quickly and remotely when distance 
or conflict would otherwise stall a good choice. 
In plain terms, any consequential decision about a person’s life, liberty, health, home, 
finances or close relationships must be authorised by two independent keys (co-sign) or an 
MPG quorum. Each decision carries a short Reasons & Weighting note and a will-and-
preferences record. Tier-0 emergencies allow immediate action to make safe, but must be 
logged within 24 hours and reviewed within 72 hours; contested or liberty-reducing matters 
trigger DSC file-vs-field calibration. 
Two-Key is not bureaucracy. It is an act of respect - for the person, for families, and for those 
who carry legal responsibility. It trades solitary certainty for shared judgement. It widens the 
circle just enough that power is less likely to miss the truth sitting in front of it. If we mean 
what we say about safety, dignity and ordinary lives in public, then we owe our best thinking 
- and we owe it together. 
 
How to use it now (no omnibus legislation required).  
 
Two-Key is switched on through existing levers: a Tribunal Practice Note, an OPA/OPG 
Investigations Code addendum, a Procurement Direction that stands up an Independent 
Pairing Pool (IPP) with a 72-hour pairing SLA (tele-co-sign allowed), and dashboard tiles 
that publish privacy-safe coverage and timeliness. Copy-ready templates (R&W short form, 
Will-and-Preferences, Tier-0 Log, DSC memo) are provided in the appendices so services 
and tribunals can adopt the same pattern on day one. 
 
Where it lives in this paper. Definitions and design principles name the safeguard; a 
standalone Shared Decision Standard  -  Two-Key Guardianship sets the rules; cross-links 
appear in Independent Verification, Governance/Assurance, Service Model, Data & 
Dashboards, and the Implementation Roadmap; appendices contain the practice note, code 
addendum, procurement/IPP SLA, dashboard specifications, and ministerial talking points. 
 

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Why firmness  -  because this is the coalface, and every decision lands on a person’s life. 
 
The day-to-day micro-hierarchy around a person with cognitive disability  -  who plans, who 
decides, who documents, who shows up  -  sets the ceiling on their life. If that hierarchy 
tolerates thin knowledge, weak supervision, loose ethics, or paper competence, the most 
regular, trusted contact will fail by design. Care is a given; evolution is the right: visible 
presence in community, real roles, relationships, health, learning, contribution. We already 
demand rigour where the stakes are obvious; we must do no less here. 
Ask yourself: would we accept an air-traffic controller with weekend courses guiding 
crowded skies; an electrician wiring a hospital after a handful of online modules; a childcare 
educator without observed practice and renewal; a paramedic cleared for ketamine without 
live simulations and sign-offs; a bridge engineer stamped competent on the strength of a title, 
not a test; a chef handling severe allergens without drills and consequence; or a pilot, 
firefighter, nuclear-medicine tech, or power-grid operator whose licence never expires?  
Of course not  -  because lives and futures depend on mastery being proven, re-proven, and 
supervised. 
Cognitive disability practice carries the same stakes  -  and the risks are concrete: aspiration 
and choking at mealtimes; unmanaged seizure thresholds and status epilepticus; medication 
interactions and cumulative sedation; chemical and mechanical restraint drifting into 
unlawful practice; positional asphyxia; missed dental infections tipping to sepsis; untreated 
pain presenting as “behaviour”; domestic-violence escalation during “welfare checks”; 
homelessness or criminalisation when supports break; financial abuse through poor 
safeguards; guardianship orders or restrictive placements that were avoidable; lost schooling, 
lost work, lost relationships. Titles cannot substitute for required competence; loyalty cannot 
substitute for learning. The IDC, DSC and Two-Key standard aligns this field with every 
other high-stakes vocation: deep preparation, specialised knowledge, observed competence, 
real supervision, periodic renewal  -  and reasons you can publish. 
For too long, safety has been treated as a checkbox: meet the minimums, hit the KPI, file the 
protocol. That is not safety; it is paperwork. When high-stakes professions harm someone’s 
future, there are consequences. 
This standards refresh resets the standard to match the stakes: 
 
Personhood first, not paperwork: safety is the beginning, not the ceiling; the aim is the 
ongoing of life  -  health, relationships, roles, learning, presence in public. 
 
Outcomes over optics: KPIs describe real life (mealtime safety passed, seizure plan used, 
community presence achieved, communication access working, foundational health standards 
met), not just completed forms. 
 
Duty of care with teeth: temporary de-rostering on serious failure; loss of licence for repeated 
or egregious breaches; 72-hour learning reviews after restraint/sedation; morbidity and 
mortality reviews for serious harm; civil liability and, where warranted, criminal referral; 
documented remediation plans monitored by an external supervisor; restitution and supports 
for the person. 

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Transparency by default: public, de-identified dashboards; published sanctions; phoenix 
controls to stop re-branding around failures. 
 
Everyday health foundations: (so restraint is not the only lever) 
A regulated healthy diet, regular exercise, movement or physio, sleep hygiene and social 
connection are not extras; they are the floor for wellbeing and for reducing behaviours of 
concern. Overuse of hand-held devices and certain social-media patterns is now associated 
with measurable cognitive, mood and sleep impacts across populations. We are not returning 
to the past; we are evolving practice: scheduled breaks, supported alternatives and digital 
habits that protect attention, sleep and motivation  -  so healthy minds match healthy bodies.  
 
These standards must live in supervision, rosters, handovers and reviews, or they do not exist. 
 
People with cognitive disability deserve the same respect society gives to passengers on a 
plane, patients in an operating theatre, children in early learning and families driving across a 
bridge: deep preparation, observed competence, real supervision and consequences when 
standards are broken. Minimums are not enough. The IDC, DSC and Two-Key standard 
makes sure our systems act like lives and futures are on the line  -  because they are. 
 
Presence in public  -  from restoration to upgrade 
 
Decades ago following the deinstitutionalisation era people were visible in public life: 
tailored jobs and micro-enterprises; clubs and teams; libraries and galleries; faith gatherings, 
markets and parks. Plans were living documents across work and learning, recreation and 
fitness, food and sleep, communication and relationships, travel and way-finding. In too 
many places, that visibility has faded. Minimal qualifications, risk-averse routines and a fill-
the-shift economy have pulled people back indoors. 
 
We are not “going back”. We complete the original turn outward and upgrade it  -  from 
sporadic outings to a measurable, everyday presence in ordinary places; from program notes 
to roles that change local economies and local culture for the better. 
Why presence pays  -  the inclusion dividend (for everyone)… 
 
When people with cognitive disability are out and about  -  as neighbours, customers, co-
workers, volunteers, artists, athletes, committee members  -  whole communities get better at 
being communities. Person-led choices reflect interests and pace (fandoms, faiths, 
subcultures, hobbies), not staff convenience. 
 
Supported risk: “ordinary risks” are managed, not avoided; learning plans trump “no” plans. 
 
The benefits are real, local and compounding: 
 
• Micro-economies grow. 
• Community capability scales up. 
• Culture and trust deepen. 
• Public systems get smarter (and cheaper). 
• Fewer crises: skilled, everyday presence reduces police/ED call-outs, emergency 
sedations and preventable admissions. 
 

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Better handshakes: regular contact with GPs, dentists, pharmacists, libraries, sports clubs and 
transport catches small issues early. 
Stronger democracy: councils, boards and juries that include people with disability make 
better rules for everyone  -  plain language, practical signage, uncluttered processes. 
 
We operationalise presence (and prove it) 
 
• Make presence part of the job. 
• Make access part of the place. 
• Make the economics visible. 
• Keep dignity central. 
 
Upgrade as a baseline 
 
We finish the original project and future-proof it: person-first practice that is public, patterned 
and measurable; roles that create value; access that benefits everyone; and a feedback loop 
that keeps improving because it is seen. Presence is not a nice-to-have. It is the operating 
system of an inclusive society and a growing local economy  -  and people with cognitive 
disability are co-designers, not passengers. 
 
Where micro-institutional settings have pulled people back behind closed doors, this paper 
makes community presence a standard, not a luxury. It introduces a Community Presence 
Index (CPI) and a minimum out-of-home participation floor (with clinical exceptions 
documented), and rewires workforce, funding and accountability so participation is 
measured, learned from and improved  -  in public, not only at home. 
 
Integrity by design (the “white elephant” problem, plainly) 
 
Across the system, dishonesties and routine corner-cutting have crept in. Habits shift 
compasses; requests and claims are inflated “just in case”; capacity is “held”; budgets lean on 
stretched or stale assumptions; rosters and claims do not match; incident notes protect the 
service first. Good people get used to bad habits because “that’s how it works”. When 
everyone quietly moves the goalposts, public trust collapses and the person with disability 
pays the price. 
 
Why it happens (no scapegoats) 
 
Uncertainty: funding rules change, people fear being left short, so they over-ask. 
Perverse incentives: paying per hour without strong checks invites hour inflation. 
Complexity: many systems and logins, manual data entry, staff churn  -  mistakes become 
drift. 
Fear: workers worry that honest reporting will trigger blame, so problems are hidden. 
The fix: treat honesty like engineering, not preaching 
 
We redesign the system so the truthful thing is easy and the dishonest thing is hard. Five tools 
do the heavy lifting: 
 
1. Two-party e-receipts (participant/nominee and worker) with time/date/location, 
accessible attestation for AAC users, and 48-hour sync. 

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2. Roster-to-claim cross-checks for impossible hours, duplicate providers, travel 
anomalies, price gaps and frequency drift. 
3. Documentation integrity via a gold-standard note exemplar, a scoring rubric and 
randomised audits that feed supervision. 
4. A visible sanctions ladder with phoenix controls and published debarments for repeat 
or egregious conduct. 
5. Protected whistle-blower channels and targeted incentives for substantiated cases. 
 
Truth is restored by design, and it stays restored because people can see the system telling the 
truth. 
 
A one-minute example (before and after) 
 
Before. A worker finishes a shift at 3:30 pm but claims 4:00 pm. The roster shows 3:30; the 
invoice shows 4:00; the participant never sees either. The claim is paid. Over time this “half-
hour” becomes normal. The person’s plan runs short. Family wonders why. 
 
After. At 3:32 pm the worker opens the app. It shows start 1:01 pm, end 3:32 pm, location 
“Park and Library”, and two bullet points: “bus travel training” and “library membership 
created”. The participant presses “Yes” on the AAC screen. Both receive a copy. When the 
provider submits the claim, the system cross-checks: roster 1:00-3:30 vs e-receipt 1:01-3:32; 
difference under five minutes  -  auto-OK. If it had been 30 minutes over, it would flag for 
quick correction. No guesswork. No padding. 
 
What this is not 
• Not “gotcha”. The aim is accuracy, not punishment. 
• Not surveillance of private life. GPS confirms work, not personal movements. 
• Not extra paperwork. E-receipts replace paper timesheets and cut disputes. 
• What gets published (so trust can grow) 
 
Quarterly, de-identified dashboards will show: percentage of claims backed by two-party e-
receipts; error rate by category (time, location, price, duplicate); correction and recovery 
amounts; documentation integrity pass rates by provider; sanctions taken (counts by level) 
and phoenix blocks applied; whistle-blower reports received and actions taken; and positive 
indicators (fewer repeat hearings, fewer ED presentations) linked to integrity. 
 
Emergency and justice interfaces  -  least-restrictive by default 
 
Defaulting to chemical or physical restraint  -  or to sedate first and ask questions later  -  is 
not a future we should accept. The standards refresh embeds a crisis standard that prioritises 
de-escalation, communication and low-arousal approaches; requires standard handover 
templates for mealtime/IDDSI, seizure protocols and medication reconciliation so EDs and 
wards, emergency services and first responders never “start from zero”; and mandates 
automatic 72-hour learning reviews for any restraint or sedation across police, ambulance and 
health. Custody health mirrors these checks and ensures continuity on release. 
 
Financial, human and future dividends 
 
The fiscal case is strong on conservative settings. Year-one savings flow from fewer repeats 
and appeals, avoided crises and hospital presentations, and integrity uplift; compounding 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 32 
 
benefits accrue as dashboards, enforcement bulletins and transparent licensing shift demand 
toward competent providers. Safety improves when mealtime, seizure and medication 
competencies are assessed, not assumed. Dignity rises with communication access and least-
restrictive practice. Participation grows when presence is required, planned and supported by 
people with real scope and supervision. Family and worker trust returns when contradictions 
are resolved in view and services tell the truth in real time. 
 
Future-proofing with guardrails 
 
The refresh anticipates the increasing role of AI and analytics. Guardrails are explicit: model 
documentation, decision logs, human-in-the-loop for consequential calls, bias and drift 
checks with quarantine thresholds, privacy-by-design and an explicit kill-switch. Automation 
supports human judgement; it never replaces it where rights are at stake. 
 
Systems, not scapegoats 
 
This paper is about systems, not blame. Rapid, quota-driven hiring, variable induction and 
weak supervision have touched many providers across all demographics. The answer is not to 
single out groups; it is to lift the standard for everyone, require observed competence before 
scope, and pay properly for hard, high-skill work. Volunteers remain welcome as Accredited 
Community Allies  -  trained for inclusion with zero clinical scope, operating under IDC 
supervision. Good intention is honoured; safety is protected. 
 
The minimum bar for entry and renewal 
• No coalface role sits below two years of mapped study or an assessed equivalent. 
• Observed practice is mandatory: OSCEs for safety-critical skills and field 
observations each cycle. 
• Re-validation every three years; high-risk modules refreshed on 24-36-month cycles. 
• Transitional RPL is time-limited and conditional; safety OSCEs are never waived. 
• Independence and conflict rules are enforced: coordination is not bundled with 
provision; behaviour-plan authorship/implementation are separated from authorisation 
by time-limited panels. 
 
Dignity, difficulty and proper pay 
 
This vocation is among the hardest: intimate personal care; communication across diverse 
modalities; behaviour understood and supported; vigilance in bowel, skin, sleep and nutrition; 
risk management in ordinary places; crisis de-escalation; and the patience to build roles and 
relationships over months and years. We do not ask average people to carry this load without 
proficiency and qualification, supervision and fair wages. Higher pay tied to observed 
competence and renewal is overdue  -  and funded by savings already leaking from weak 
practice and weak integrity. 
 
Person-first, in public  -  again 
 
Deinstitutionalisation in Australia wasn’t a switch we flipped; it was a long unravelling that 
actually began in the 1950s and 60s, when people were discharged from psychiatric hospitals 
into communities that mostly weren’t ready for them. Through the 70s and early 80s a 
coalition of psychiatrists, psychologists, families and advocates pressed for a different future, 
and the idea of care-in-community began to take shape. The Richmond Report in New South 

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Wales (1983) put words to that shift, urging the staged closure of large institutions and 
investment in community supports. A decade later the Burdekin Report (1993) named the 
human rights failings of the old system and cemented the national direction. By the late 1990s 
and into the 2000s most of the big hospitals were gone - Victoria, for example, closed all 
fourteen of its standalone psychiatric hospitals between 1994 and 2000 - and group homes, 
clinics and community teams became the norm. 
 
But the bricks came down faster than the bridges went up. Too often the new supports were 
thin, patchy or late, and many people and families were left to navigate gaps that policy 
hadn’t yet closed. That mixed legacy matters. We did the right thing by stepping away from 
life behind locked doors; now we finish the job by making life in public real - funded, staffed, 
and proven in ordinary places. We recommit to a society where people with cognitive 
disability are seen, known and expected in community, because that is how barriers of 
culture, class, fear and ignorance finally fall; how “different” becomes familiar; and how we 
move from arguments about “fitness” to an ethic of care that lifts us all. 
 
This demands the compassion Andrew Boyd names - “strong enough to love the world, yet 
empty enough to sit with its worst horrors” - but redirected: no more sitting with horrors. 
Design them out, prevent them, and repair what they’ve broken. 
  
 
In plain Australian terms: if we all “put in”, every boat can rise. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

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Executive Summary 
 
What changes now 
• Dissolve “Direct Care” titles. Every coalface role moves to the Integrated Disability 
Clinician (IDC) pathway with mapped curriculum, observed practice, and periodic 
renewal (OSCEs  field observation). [See Workforce Standard  -  Integrated Disability 
Clinician (IDC).] 
• Make “least-restrictive by default” real. Adopt a restraint hierarchy with timekeeping 
and mandatory 72-hour learning reviews. [See Safety & Restrictive Practices 
Standard.] 
• Build truth-by-design. Two-party e-receipts, roster-to-claim cross-checks, and a 
proportionate sanctions ladder - less paperwork, more integrity. [See Truth-by-Design 
Standard.] 
• Add independent verification. A Decision Support Consultant (DSC) function 
provides file-vs-field calibration in contested/high-risk matters and supports published 
plain-English reasons. [See Independent Verification Standard.] 
• No one decides alone (Two-Key Guardianship). Consequential decisions about a 
person’s life, liberty, health, home, finances or relationships require two independent 
keys (co-sign) or an MPG quorum (multi-person guardianship: 2/3 for most decisions; 
3/3 where liberty is reduced). A short Reasons & Weighting note and 
will-and-preferences record accompany each decision; DSC calibration is engaged for 
contested/high-risk calls. Emergencies run on a Tier-0 exception (make safe), logged 
within 24 hours, with a 72-hour learning review. 
• Separate coordination from provision; make switching easy. Plans and dashboards in 
Plain English and Easy Read. [See Service Model Standards (life in community).] 
• Deliver in phases using existing powers (practice notes, procurement, program rules) 
with transparent dashboards - no omnibus legislation required to pilot. [See 
Implementation Roadmap (Switch-On Order).] 
 
Why this matters 
 
The coalface worker is often the most regular adult in a person’s week. Proficiency, 
judgement, and ethics at the frontline predict safety, presence in ordinary places, and long-
term outcomes. Current infrastructure lacks adequate solution. A person-first standard with 
real practice (not screens-as-care, not restraint as default) improves health, belonging and 
contribution - in public, not hidden at home. [See Service Model Standards (life in 
community) and Evaluation & Continuous Learning.] 
 
 
Year-one effects (base case) 
• Fewer repeats/appeals; avoided sentinel events; fewer preventable hospitalisations and 
ED presentations; reduced medication misadventures. 
• Measurable uplift in community presence (minutes/hours in ordinary places), goal 
attainment, and carer confidence. 

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• Market shift toward competent providers through visible quality signals and calibrated 
verification. [See Finance & ROI Case and Appendix: Finance & ROI workbook 
notes.] 
 
Guardrails 
• Supported decision-making; least-restrictive tests embedded in hearings/program 
rules; published reasons with an auditable “Reasons & Weighting” template. 
• Independent DSC calibration (file-vs-field, not title-vs-title); plain-language appeal 
pathways. [See Independent Verification Standard; Truth-by-Design Standard; 
Governance, Assurance and Risk.] 
• Two‑Key Guardianship failsafe: co‑sign coverage ≥ 98%; median co‑sign ≤ 48h; 
Tier‑0 exceptions documented ≤24h and reviewed ≤72h; rural parity via a state-wide 
Independent Pairing Pool (IPP) with 72‑hour pairing SLA (tele‑co‑sign permitted); 
privacy‑safe publication with n<5 suppression. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
White paper basics: 
 
• If you need the “what changes now” view: Start with the Executive Summary. 
 
• If you deliver services: Read Workforce (IDC), Safety & Restrictive Practices, and Truth-by-
Design, then check Implementation Roadmap for sequencing. 
 
• If you oversee decisions: Read Independent Verification Standard and Governance, 
Assurance and Risk. 
 
• If you measure outcomes or fund programs: Read Data, Dashboards and Privacy; then 
Finance & ROI Case and Evaluation & Continuous Learning. 
 
• If you are a family or supporter: Start with the Foreword and Service Model Standards (life 
in community), then the Easy Read, Crosswalks elements and family-view dashboard notes. 
 
This white paper is layered on purpose: 
 
• Main body  -  what to do and why. 
• Appendices  -  detail, tests and standards when the body isn’t enough. 
• Crosswalks & Templates  -  ready-to-use tools when the appendix still isn’t enough. 
 
Together they provide a baseline, not a ceiling. Use them as a starting point you can extend, localise 
and improve - provided changes remain auditable and consistent with the standards in this paper. 

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Purpose, Scope and Audience 
 
Purpose 
 
This white paper translates principles into enforceable, auditable, day-to-day standards for 
people with intellectual disability (ID) and acquired brain injury (ABI) and closely related 
cognitive-communication conditions. It does this by: 
 
• Professionalising the frontline via the Integrated Disability Clinician (IDC) pathway 
(mapped curriculum, observed practice, renewal). [See Workforce Standard  -  
Integrated Disability Clinician (IDC).] 
 
• Making least-restrictive the default through a restraint hierarchy, timekeeping, and 
mandatory 72-hour learning reviews with fade plans. [See Safety & Restrictive 
Practices Standard.] 
 
• Embedding truth-by-design (two-party e-receipts, roster-to-claim cross-checks, 
sanctions ladder) so integrity improves without extra paperwork. [See Truth-by-
Design Standard.] 
 
• Adding independent verification through a Decision Support Consultant (DSC) 
function that calibrates file-vs-field and supports published plain-English reasons. 
[See Independent Verification Standard.] 
 
• Publishing progress on open dashboards so families, services and ministers can see 
change in real time. [See Data, Dashboards and Privacy.] 
 
What success looks like 
 
• Safety and rights: Avoided sentinel events; fewer restrictive minutes per 1,000 
support hours; timely 72-hour reviews; documented alternatives; fewer medication 
misadventures. 
 
• Presence in ordinary places: More minutes in community settings; improved goal 
attainment; stronger carer confidence. 
 
• Market quality: Higher IDC competence signals; visible verification; reduced 
fraud/error through e-receipt coverage. 
 
• System learning: Quarterly publication, peer calibration, red-team stress tests; fewer 
repeats/appeals. 
[See Evaluation & Continuous Learning and Finance & ROI Case.] 
 
Scope (what’s in) 
• People: Children (incl. developmental delay), adolescents and adults with ID/ABI and 
related cognitive profiles; their families and supporters. Priority cohorts: First 
Nations; CALD/Auslan; AAC users; paediatrics; justice-involved; people at risk in 
mealtime/IDDSI and psychotropic contexts; rural/remote. 

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• Settings: Home and community; education; primary and acute health; ED and 
planned care; transport; justice interfaces (police, courts, custody/corrections, 
release); out-of-home care/child protection; housing/homelessness; mobile 
clinic/telehealth; rural and remote. 
 
• Standards and tools: IDC workforce standard; restraint hierarchy and 72-hour 
learning reviews; DSC file-vs-field verification; Two-Key Guardianship; Right-to-
Reasons, IRC and Contradiction Matrix; AA Crosswalks; R-series DPIA & AI safety; 
S-8 publication/change-log; T-series provenance/audit; e-receipts (E-series) & 
roster↔claim cross-checks (F-series); psychotropic stewardship (AB-series); dental 
(AC-series); transport (AE-series); police integration (AN-series); accessible plans 
(K-series); interpreter/Auslan/AAC (N-series); First Nations partnership (O-series). 
 
• Participation & consent: Supported decision-making; navigator coverage; least-
restrictive  fade; plain/Easy Read reasons. 
 
• Measurement & release: Tiles with quarterly cadence; small-cell suppression for 
public outputs; visible change notes (S-8). 
 
• Time horizon: Immediate pilots; 12-24-month scale-up; 36-60-month consolidation 
and refresh. 
 
• Policy alignment: Integrates with mainstream early-supports (e.g. early childhood 
streams) without waiting for omnibus legislation. 
[See Implementation Roadmap (Switch-On Order).] 
 
Boundaries (what’s out) 
• Funding instrument design and eligibility architecture (NDIS/Medicare settings). 
We’re not redesigning how money flows or who qualifies. That’s a government job. 
Instead: we define the practice standards and interfaces that work with whatever 
funding rules exist. 
 
• Clinical prescribing/treatment guidelines beyond safety, stewardship and hand-
over requirements. 
We don’t tell clinicians what drug or therapy to choose. 
Instead: we set safety rails (e.g., psychotropic stewardship, mealtime/IDDSI) and 
clean hand-over expectations. 
 
• New jurisdictions or statutory powers. 
We’re not creating new courts/regulators or changing legal powers. 
Instead: we specify standards, verification, and publication that fit within today’s 
powers. 
 
• Procurement/vendor selection or bespoke IT builds. 
We don’t pick products or build custom platforms. 
Instead: we provide minimum data specs, APIs, and templates any compliant tool can 
implement. 

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• Individual case decisions or legal advice; industrial relations policy; 
building/compliance codes. 
We won’t judge single cases, give legal advice, set pay/award policy, or rewrite 
building codes. 
Instead: we supply decision-quality tools (Right-to-Reasons, IRC, Contradiction 
Matrix) and point to the correct external rules. 
 
• Collection of identifiable data beyond DPIA-cleared minimum; all public 
releases apply small-cell suppression. 
We don’t collect or publish more personal data than necessary. 
Instead: we follow DPIA, hash/provenance patterns, and suppress small cells in 
public releases. 
 
• Where relevant, this paper specifies interface requirements and hand-over 
standards rather than rewriting adjacent systems. 
We connect to health, justice, education, housing as they are, with clear “who hands 
what to whom, when, and how”. 
We publish crosswalks and templates that make those joins safe and auditable - no 
system rewrites required. 
Audience 
 
• People and families: Plain-language orientation, Easy Read cues, and family-view 
dashboards to support choices and dignity of risk. [See Service Model Standards (life 
in community).] 
 
• Frontline workforce: IDC candidates and supervisors - how to meet the standard, 
pass OSCEs, and maintain renewal. [See Workforce Standard  -  Integrated Disability 
Clinician (IDC).] 
 
• Providers and commissioners: Procurement, onboarding, audit/assurance, sanctions 
ladder, and publication rules. [See Governance, Assurance and Risk.] 
 
• Tribunals, public advocates /trustees and ombudsman services: Reasons & 
Weighting template, Contradiction Matrix, DSC calibration, and publication of plain-
English reasons. [See Independent Verification Standard.] 
 
• Ministers and central agencies: Delivery milestones, dashboards, ROI workbook, 
and risk controls. [See Finance & ROI Case; Implementation Roadmap (Switch-On 
Order).] 
 
Non-negotiables 
• Person-first and least-restrictive by default. 
Start with what the person wants and can do; choose the smallest, safest support that 
works; fade controls quickly. 
 

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• Truth-by-design controls, not after-the-fact fixes. 
Build verifiable steps into the work (timers, double-checks, hashes, logged reasons) so 
errors surface early and visibly. 
 
• Independent verification with published reasons. 
A second, independent reader checks the file and field match; a short Right-to-
Reasons note is published (plain  technical). 
 
• Separation of coordination from provision; easy switching. 
The coordinator isn’t the provider. If care isn’t working, the person can switch with a 
warm hand-over and no penalty. 
 
• Equity and rural parity. 
First Nations partnership is built in; CALD/Auslan and AAC are offered up-front; 
rural services get micro-hubs, tele-OSCEs, and scholarships so quality matches metro. 
 
• Privacy-by-design and open, auditable data. 
Collect the minimum data, run a DPIA, hash and log changes, and apply small-cell 
suppression; publish de-identified tiles and visible change notes. 
Terminology and conventions 
• IDC (Integrated Disability Clinician) knowledge requirement 
The practitioner trained to the IDC standard (assessment, communication access, 
least-restrictive practice, 72-hour learning). 
 
• DSC (Decision Support Consultant) 
A neutral verifier who tests “file vs field”, runs the contradiction matrix, and attests 
reasons (does not provide the service they verify). 
 
• Two-Key Guardianship 
High-impact decisions require two independent “keys” (roles) to agree, with 
abstention and a reversible warrant; emergencies are time-boxed and reviewed within 
72 hours. 
 
• Review 
Unless stated otherwise, means a 72-hour learning review using the B-series 
templates (facts → why → what changes). 
 
• E-receipt 
A two-party attested receipt (provider  family/authorised person) with role-based 
visibility, tied to the audit log and small-cell publication rules. 
 
 
 
 

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Method (for readers who want the blueprint behind the blueprint) 
 
Upgrade the 12-24-month ROI plan into a systems-grade program that integrates policy, 
economics, clinical governance, market design, behavioural science, data/AI, law and ethics - 
so choices are coherent, trade-offs transparent, and results verifiable in public. 
 
Method 
 
Open methods, named controls, publishable signals (OSCE curriculum map; restraint 
timekeeping and 72-hour reviews; e-receipts coverage; CPI movement; MIS/IRC use; DSC 
calibration variance). [See Implementation Roadmap (Switch-On Order); Data, Dashboards 
and Privacy; Evaluation & Continuous Learning.] 
 
Scope & Boundaries 
 
• Who. Children, young people and adults with cognitive disability (ID, ABI and 
related profiles), their families, and the frontline workforce. 
 
• Where. Mainstream and specialist settings - home, community, education, health, 
justice, rural/remote. 
 
• In-scope. Workforce standards (IDC), least-restrictive practice, truth-by-design 
controls, independent verification, dashboards, finance/ROI, and governance. 
 
• Out-of-scope. Benefit design; long-form legislation changes (pilots rely on existing 
powers); clinical prescribing protocols (except restraint hierarchy, handover and 
monitoring). 
 
• Sequencing. Pilot > verify > publish > expand; avoid “big-bang.” [See 
Implementation  
• Roadmap (Switch-On Order).] 
 
Design principles 
• Person-first, least-restrictive by default. Reduce and eliminate restrictive practices; 
time-bound learning reviews; fade plans. [See Safety & Restrictive Practices 
Standard.] 
• Truth by design, not after-the-fact. Two-party e-receipts, roster-to-claim cross-
checks, sanctions ladder; publish quality signals by default. [See Truth-by-Design 
Standard.] 
• Independent verification. DSC calibration attached to tribunal/public advocate 
Reasons & Weighting and a Contradiction Matrix. [See Independent Verification 
Standard.] 
• No one decides alone. Where a decision would materially affect life, liberty, health, 
home, finances or close relationships, it is authorised by two independent keys or an 
MPG quorum, with a plain‑English reasons note, a will‑and‑preferences record, and 
contestability through DSC calibration. 
• Equity and rural parity. Micro-hubs, tele-OSCEs, scholarships; CALD/Auslan 
access; First Nations partnership. [See Equity, First Nations Partnership and Access.] 

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• Separation of powers in services. Coordination independent from provision; easy 
switching; dashboards for families. [See Service Model Standards (life in 
community).] 
• Open, privacy-safe data. Minimum schemas, suppression rules, DPIAs, immutable 
audit logs. [See Data, Dashboards and Privacy.] 
• Calibration and renewal. OSCEs; licensure register; de-rostering rules; quarterly 
peer-review; red-team stress tests. [See Governance, Assurance and Risk; Evaluation 
& Continuous Learning.] 
Policy alignment signal (why this is timely) 
 
The Commonwealth’s Thriving Kids initiative (0-8, mainstream early supports) and related 
reforms provide a natural entry point for pilots and funding alignment commencing 1 July 
2026. The program is designed to plug into these cycles rather than wait for omnibus 
legislation. [See Implementation Roadmap (Switch-On Order).] 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
[See “Independent Reasoning Certificate”]  
 
 
Spotlight: reasons & appeal-ready records 
 
Why this matters now 
People cannot appeal what they cannot see. An order is only “appeal-ready” once the record is 
served. This paper provides transplant-ready templates and a short model clause that pauses 
(“tolls”) the appeal clock until the full record is in hand. 
 
Minimum “appeal-ready record” 
1) Written reasons (plain-English and Easy-Read if requested); 
2) Reasons & Weighings (R&W) table that shows how evidence was balanced; 
3) Contradiction Matrix entry where file vs field realities diverge; 
4) Independent Reasoning Certificate (IRC) signed by the decision-maker or reviewing officer; 
5) Schedule of exhibits / relied material (with any sensitive redactions itemised). 
 
Model rule (short) 
The time for any review/appeal does not begin to run until service of the complete appeal-
ready record listed above. 
 
Publication cadence 
De-identified reasons + R&W tables are published quarterly, with tile counts (reasons issued; 
time-to-reasons; % with IRC) on the public dashboard. 
 
See also 
• Open reasons & appeal-ready records  
• Templates: R&W table; Contradiction Matrix; IRC 
• Dashboard tiles: reasons publication, time-to-reasons, restraint minutes 

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Small policy-tracker tab 
 
 Item / Review   Status (short) Link Last 
check 
QLD QCAT Act review 
2025-26 
Open; papers Sep-Nov 2025; final 
report due 30 Apr 2026 
https://www.justice.qld.gov.au/initi
atives/qcat-act-review-2025-26 
11 Sep 
2025 
WA LRCWA Project 114  
-  Guardianship & 
Administration 
Discussion Paper Vol 1 released; 
review in progress 
https://www.wa.gov.au/government
/publications/project-114-
guardianship-and-administration 
11 Sep 
2025 
VIC VCAT Practice Notes 
(reasons, common 
procedures) 
Practice notes in force; reasons 
guidance via PNVCAT1 
https://www.vcat.vic.gov.au/practic
e-notes 
11 Sep 
2025 
 
Those outside the early-years stream - how we close the gaps 
• Age 9-17 (school-age). Avoid “ageing out” cliffs; embed school-community practice 
with coordinated IDC support. 
• 18+ and older adults. Smooth transitions, employment-readiness, community 
presence targets, and health/medication reconciliation. 
• Justice and acute interfaces. Standard handovers; hospital/ED reconciliation; 
custody/corrections continuity. [See Service Model Standards (life in community); 
Safety & Restrictive Practices Standard; Data, Dashboards and Privacy.] 
Ethics, rights, privacy and AI 
• Rights & least-restrictive tests. Mandatory review triggers, documented alternatives, 
family/guardian visibility. 
• Privacy & DPIA. DPIAs for all data flows; open schemas with role-based access; 
immutable logs; family-view dashboards (with suppression rules). 
• Human-in-the-loop analytics. No black-box decisioning; published model cards 
where analytics are used. [See Truth-by-Design Standard; Data, Dashboards and 
Privacy.] 
Measurement, milestones & go/no-go gates 
 
Dashboards (quarterly). Licensing and OSCE pass rates; CPI change; restraint minutes/1,000 
support hours; review compliance; e-receipt coverage; visibility in ordinary places. (Family 
view and public tiles with suppression rules.) 
Milestones. 
• 0-3 months: Practice notes issued; DSC service stood up; e-receipt pilot; restraint 
timekeeping live; dashboard v1. 
• 3-6 months: First OSCEs; early rural micro-hubs; tele-OSCEs; sanctions ladder in 
force; tribunal Reasons & Weighting templates mandated. 
• 6-12 months: Scale pilots; publish de-identified dashboards; ROI workbook live; 
peer-review & red-team cycle 1. 
Go/No-Go gates. Progress only when QA checks = ALL_OK and privacy/AI 
conformance passes. [See Implementation Roadmap (Switch-On Order); Evaluation 
& Continuous Learning; Data, Dashboards and Privacy.] 
 

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Open reasons & appeal-ready records hub 
 
Purpose 
 
This hub makes it easy to adopt “candour by design”: clear reasons, a complete appeal-ready 
record, and a predictable publication cadence - without creating extra paperwork or 
guesswork. 
 
What is an appeal-ready record 
 
1) Written reasons (plain English; Easy-Read if requested). 
2) Reasons & Weighings (R&W) table showing how evidence was balanced. 
3) Contradiction Matrix entry where file and field realities diverge. 
4) Independent Reasoning Certificate (IRC) signed by the decision-maker or reviewing 
officer. 
5) Schedule of exhibits relied upon (with any redactions itemised). 
 
Service rule (short) 
 
The appeal clock starts on service of the complete appeal-ready record (above) in an 
accessible form. 
 
Publication cadence (open justice) 
 
• Quarterly de-identified releases of reasons and R&W tables.   
• Tile metrics published with each release: time-to-reasons (median), % decisions 
with R&W, % with IRC, % with contradiction analysis (where applicable).   
• Registry checklist ensures service date, accessibility format, and publication 
schedule are met. 
 
Templates & checklists (use these, not free-text) 
 
• Reasons & Weighings (R&W) table  -  [cross-reference to template heading]   
• Contradiction Matrix  -  [cross-reference to template heading]   
• Independent Reasoning Certificate (IRC)  -  [cross-reference to template heading]   
• Registry Checklist (service, accessibility, publication)  -  [cross-reference to 
checklist heading]   
• Practice-note transplant  -  [cross-reference to “Practice Note: Reasons & Appeal-
Ready Records”] 
 
Data & dashboards (what tiles to publish) 
 
Minimum tiles (public): 
 
• Time-to-reasons (median days)   
• % decisions with R&W table   
• % decisions with IRC   
• # reasons published this quarter 
 
Minimum tiles (internal QA): 

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• % decisions with contradiction analysis when file/field diverged   
• % appeal-ready records served within statutory timeframe 
 
Privacy & de-identification 
 
Publish de-identified reasons and tables; maintain an internal register linking source matters 
to published artefacts. Redactions follow the registry’s standard, recorded in the exhibits 
schedule. 
 
30/60/90-day switch-on (practical) 
 
• 30 days: adopt templates; train registry on the checklist; set up tile extracts.   
• 60 days: first de-identified quarterly batch; publish tiles; run spot-checks.   
• 90 days: audit sampling; publish improvement notes and next-quarter targets. 
 
 
 
How Ministers can message this 
 
Open justice: reasons in plain English,  
appeal-ready records by default,  
and quarterly public tiles. 
 
30-second grab  
 
Australia can do two things at once:  
keep people safe and lift their daily dignity.  
We’re ending “set-and-forget” care.  
Every frontline worker will be trained and  
observed to an IDC standard; families will  
see what’s billed; and independent checks  
will verify the facts. It’s practical, auditable  
reform that puts people first and gives  
tax-payers proof. 
 
90-second stand-up 
• Safety and dignity first. Least-restrictive by default; serious incidents trigger a 72-
hour learning review with the family looped in. 
• A workforce you can trust. We replace generic “direct care” titles with the 
Integrated Disability Clinician (IDC) path: mapped study or equivalency + observed 
practice + 3-year renewal; rural micro-hubs ensure parity. 
• Truth by design. Two-party e-receipts, roster-to-claim cross-checks and a clear 
sanctions ladder reduce waste without extra paperwork. 
• Independent verification. A neutral Decision Support Consultant (DSC) checks file-
vs-field facts so tribunals and agencies can publish plain-English reasons. 
• Appeal clock runs from record, not rumour: reasons + R&W + IRC served to start 
time. 
 
“Numbers to remember” 
  
• 2 years mapped study (or assessed 
equivalent) to work safely at the 
coal-face. 
• 3-year licence renewal; high-risk 
refreshers every 24-36 months. 
• 8-12 hours/week minimum community 
presence (with clinical exceptions 
documented). 
• 72 hours for a learning review after any 
restraint or sedation. 
90 days for the pilot plan; 120/60/30-day 
renewal reminders for licences. 

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• No one decides alone. Authorised by two independent keys or an MPG quorum, with 
a plain‑English reasons note, a will‑and‑preferences record, and contestability through 
DSC calibration. 
• Choice, equity and access. Coordination is independent from provision; plans are in 
Easy Read; CALD/Auslan and First Nations partnerships are built-in. 
Thirteen plain-language points 
1. Least-restrictive by default; restraint fades are time-bound and reviewed. 
2. Families see what’s claimed via two-party e-receipts. 
3. Every worker follows the IDC path (or mapped equivalency). 
4. Observed practice matters as much as theory (OSCE/EPAs). 
5. Independent DSC checks resolve contested facts early. 
6. Coordination separated from provision to protect choice. 
7. Two-Key Guardianship secures transparency and contestability. 
8. Sanctions ladder is transparent; good actors advance faster. 
9. Dashboards show outcomes with privacy-safe suppression. 
10. Rural parity through micro-hubs, tele-OSCEs and scholarships. 
11. First Nations partnership and cultural safety are non-negotiable. 
12. AI/analytics support humans; no automated adverse decisions. 
13. We publish methods and reasons in plain English. 
Common questions (one-liners) 
 
• Q: Will this add paperwork?  
A: No. We replace after-the-fact fixes with built-in checks like e-receipts and roster-to-claim 
cross-checks. 
• Q: How do I know the workforce is qualified?  
A: Every worker follows the IDC path (or mapped equivalency) and is observed in practice. 
• Q: What if I live regionally?  
A: Micro-hubs, tele-OSCEs and scholarships keep services viable and skilled in rural 
communities. 
• Q: How will I see progress?  
A: Public dashboards, quarterly quality summaries and plain-English reasons. 
• Q: Will AI make decisions about my services?  
A: No. AI can only flag; a named human makes every decision that affects access, eligibility, 
pricing or safeguards. 
 
Dependencies & risks snapshot (for executive readers) 
• OSCE capacity & supervision throughput must meet ramp. [See Governance, 
Assurance and Risk.] 
• Rural/remote parity via tele-OSCEs, mobile clinics, scholarships. [See Workforce 
Standard  -  IDC; Implementation Roadmap (Switch-On Order).] 
• Data quality & privacy. Open schemas, immutable logs, DPIAs; staged publication 
to prevent narrative capture. [See Truth-by-Design Standard; Data, Dashboards and 
Privacy.] 
• Communications risk. Proactive Plain English packs; lived-experience stories; Easy 
Read assets; public dashboards to anchor trust. [See Service Model Standards (life in 
community).] 
 

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Definitions and Principles 
 
How to read this standards refresh 
 
This section locks the shared language used throughout the paper and sets the non-negotiable 
principles that guide every standard and tool. Capitalised terms below are used consistently. 
Cross-references point to section names (not legacy numbering) to avoid drift. 
 
Definitions (terms used throughout) 
Cognitive disability (umbrella) 
An umbrella term in this paper covering conditions that affect thinking, learning, memory, 
communication, decision-making and self-management. It includes Intellectual Disability (ID), 
Acquired Brain Injury (ABI) and related profiles (e.g., developmental delay, some 
neurodevelopmental conditions) where cognitive functions are materially affected. 
Intellectual Disability (ID) 
Significant limitations in intellectual functioning and adaptive behaviour originating before age 18, 
affecting conceptual, social and practical skills. Support needs vary and may change over time. 
Acquired Brain Injury (ABI) 
Any brain injury occurring after birth (e.g., trauma, hypoxia, infection, stroke) resulting in cognitive, 
behavioural, emotional or physical changes that may fluctuate and require tailored supports. 
Least-restrictive by default 
A governing standard that the person’s rights, autonomy and inclusion take precedence. Where risk is 
present, supports must use the least-restrictive option likely to be effective, escalated only where 
necessary, and faded as soon as possible. [See Safety & Restrictive Practices Standard.] 
Restrictive practice / restraint 
Any practice that limits a person’s movement, liberty, decision-making or access to their environment 
(e.g., chemical, physical, mechanical, environmental, seclusion). In this paper: 
• Restraint hierarchy sets what is prohibited, what requires authorisation, and what requires 
timekeeping and review. 
• Timekeeping logs minutes under restraint. 
• 72-hour learning review is a mandated review within 72 hours to test alternatives, agree next 
steps and update the fade plan. 
• Fade plan documents how restraint will be reduced and removed. 
[See Safety & Restrictive Practices Standard.] 
Dignity of risk 
 
A person’s right to make choices and to learn through reasonable risk with supports in place, rather 
than being over-protected in ways that shrink life and opportunity. This paper treats dignity of risk as 
core to person-first practice. 

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Community presence and participation 
Presence: time spent in ordinary places (e.g., shops, parks, clubs, employment, education). 
Participation: active roles, relationships and contributions in those places. Both are tracked as 
outcome indicators. [See Service Model Standards (life in community).] 
Integrated Disability Clinician (IDC) 
The professionalised frontline role replacing generic “Direct Care” labels. The IDC pathway includes: 
mapped curriculum, observed practice, on-the-job Entrustable Professional Activities (EPAs) or 
equivalent, Objective Structured Clinical Examinations (OSCEs), supervised practice, and periodic 
renewal. [See Workforce Standard  -  Integrated Disability Clinician (IDC).] 
Decision Support Consultant (DSC) 
A neutral verifier who calibrates file-vs-field facts in contested or high-risk matters and supports 
publication of plain-English reasons. DSCs use standard artefacts including a Reasons & Weighting 
template (evidence table; probative value; applied tests; human rights analysis) and a Contradiction 
Matrix (sources, conflicts, resolution). [See Independent Verification Standard.] 
 
Two‑Key Guardianship 
A shared‑decision safeguard: consequential decisions require confirmation by two independent 
decision‑makers (keys) or an MPG quorum (2/3 standard; 3/3 where liberty is reduced). Each decision 
carries a short Reasons & Weighting (R&W) note and a will‑and‑preferences record. A Tier‑0 
emergency permits immediate action to make safe; it must be logged within 24 hours and reviewed 
within 72 hours with a fade/next‑steps plan. 
Multi‑Person Guardianship (MPG) 
A guardianship order that appoints two or more guardians who decide by quorum (2/3 majority; 3/3 
for liberty‑reducing decisions), with anti‑collusion rules and rotation of principal signers. 
Independent Pairing Pool (IPP) 
A state-wide roster of vetted, conflict‑screened co‑signers available within 72 hours (tele‑co‑sign 
allowed) to meet Two‑Key requirements when a second guardian is unavailable/recused; governed by 
a published SLA and rotation rules. 
Tier‑0 Emergency 
A time‑critical situation where immediate action is necessary to keep a person safe or to prevent 
serious harm. Actions must be the least‑restrictive, be time‑bound, and be logged ≤24h with a 72‑hour 
learning review. 
Two-party e-receipt 
A digital, attestable receipt confirmed by both the person/authorised representative and the provider 
for supports delivered. It includes role-based family visibility, supports AAC/accessible modes, and 
records declined items (e.g., E7). [See Truth-by-Design Standard; Data, Dashboards and Privacy.] 
Roster-to-claim cross-check 

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An automated control that matches rosters, timesheets, location signals (where appropriate and 
lawful) and claims to detect anomalies before payment. Exceptions follow proportionate review. [See 
Truth-by-Design Standard.] 
Sanctions ladder 
A transparent, proportionate set of consequences (advice → corrective plan → probation → 
suspension → contract exit/referral) tied to verified findings, with publication rules to signal market 
quality. [See Governance, Assurance and Risk.] 
Easy Read and Plain English 
Plain English: clear, active, jargon-free language. 
Easy Read: highly accessible summaries using large type, icons and short sentences for people who 
prefer simplified materials. Both are used across plans, dashboards and public communications.  
DPIA (Data Protection Impact Assessment) 
A structured assessment of privacy risks and mitigations for data flows, required for dashboards, e-
receipts and analytics. [See Data, Dashboards and Privacy.] 
Coordination independent from provision 
Support coordination (or equivalent) is structurally separated from service delivery to reduce conflicts 
and make switching providers straightforward. [See Service Model Standards (life in community).] 
 
Language conventions (style and usage) 
• Person-first (or identity-first if explicitly preferred); avoid ableist framing. 
• Noun “practice”, verb “practise”; Australian spelling throughout. 
• Review means a 72-hour learning review when used in sections dealing with restrictive 
practices. 
• Capitalise defined terms (IDC, DSC, Two-Key, Reasons & Weighting, Contradiction Matrix, 
Sanctions Ladder) for consistency. 
• Replace “Direct Care” with IDC in all contexts; avoid “babysitting”, “carer’s burden” or 
similar phrases that diminish professional skill or personhood. 
• Avoid “screens-as-care”: technology supplements but does not replace presence in 
community. 
• All cross-references use section names, not numbers, to avoid breakage during edits. 
Principles (non-negotiables that govern design and delivery) 
Person-first, least-restrictive by default 
Plan and deliver supports around the person’s goals and preferences; use the least-restrictive option 
likely to succeed; log minutes; conduct the 72-hour learning review; maintain a fade plan. [See Safety 
& Restrictive Practices Standard.] 
 
Truth by design 
 
Build integrity into the flow of work - two-party e-receipts, roster-to-claim cross-checks, immutable 
audit logs, clear publication rules - so trust improves without extra paperwork. [See Truth-by-Design 
Standard.] 

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Independent verification 
DSC calibration and tribunal/public-advocate/trustee tools (Reasons & Weighting; Contradiction 
Matrix) ensure contested decisions are transparent, replicable and explainable. [See Independent 
Verification Standard.] 
Separation of roles and easy switching 
Keep coordination independent from provision; remove switching friction; publish quality signals so 
families can act on them. [See Service Model Standards (life in community).] 
Equity and rural parity 
Design for First Nations partnership, CALD/Auslan access, and rural delivery using micro-hubs, tele-
OSCEs and scholarships so small/regional services can meet the same standard. [See Equity, First 
Nations Partnership and Access; Workforce Standard  -  IDC.] 
Privacy by design, open where safe 
Use DPIAs, role-based access, suppression rules and open schemas. Publish de-identified dashboards 
that are useful for families and accountable for providers without exposing personal data. [See Data, 
Dashboards and Privacy.] 
Continuous learning and renewal 
Quarterly peer calibration, red-team stress tests, OSCE renewals and sunset/refresh rules for 
standards. Decisions and results feed improvement loops, not blame cycles. [See Evaluation & 
Continuous Learning.] 
Proportionality and accountability 
Use a sanctions ladder tied to verified findings. Publish outcomes proportionately to signal quality and 
deter poor practice without chilling innovation. [See Governance, Assurance and Risk.] 
Ordinary places first 
Prioritise presence and participation in ordinary places over building parallel lives. Technology assists 
but does not substitute for real-world roles and relationships. [See Service Model Standards (life in 
community).] 
 
 
 
 
 
 
 
 
 
 
 
 
 

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Evidence and Drivers 
 
What the data and lived experience show 
• Safety risks persist. Sentinel events, hospitalisations and ED presentations continue; 
restraint/seclusion minutes are patchy or late; medication errors spike at transitions 
when reconciliation is thin. 
• Hidden isolation. Long stretches at home and on screens are misread as “settled”. 
Minutes in ordinary places are low; skills stall without real-world practice. 
• Documentation over life. Paper is heavy while supervision and field observation are 
light; plans are written, not practised; technology is used as a proxy for presence 
(“screens-as-care”). 
• Training-to-practice gap. Too much “learning” is online-only and unobserved; 
micro-modules/webinars replace coached practice; bridging courses and some RPL 
are tick-and-flick, producing paper competence without OSCE-level proof. 
• Low syllabus depth. Core safety domains (IDDSI/mealtime safety, seizure response 
incl. rescue-meds, medication safety, AAC in conversation, PBS fidelity, least-
restrictive practice, documentation integrity) are missing or treated as electives; 
assessment is recall-based, not observed. 
• Service delivery decline. Families report thin supervision, fill-the-shift rostering and 
churn; “support time” is diverted to housekeeping, transport, screens or paperwork; 
police/ED are used in place of skilled de-escalation. 
• Weak market signals. Families cannot see competence; capable providers gain little 
visible advantage; a minority exploit gaps while most are under-supported. 
• Tribunal, Public Advocate, Ombudsman and Public Trustee/Guardian load. 
Files and field facts diverge; complaints ping-pong between agencies; Ombudsman 
offices surface repeat systemic issues but lack routine powers to verify practice live; 
Public Trustees/Guardians (names vary by state) manage finances and, when 
appointed by a court/tribunal, personal decision-making (e.g., accommodation, 
health, services). High caseloads and risk-averse settings delay essential purchases or 
authorisations (equipment, housing adjustments) and stall participation. 
• Rural and remote inequity. Sparse workforce; limited interpreters and specialist 
input; travel/time penalties go unaddressed. 
• Financial leakage. Errors and fraud rise without pre-payment controls; incentives 
reward hours over outcomes; integrity checks are retro, not built in. 
Root causes (10 recurring failure models) 
1. Safety without learning. Restraint is used but minutes aren’t kept, 72-hour learning 
reviews don’t run, and fade plans don’t govern the next shift. 
2. Presence without participation. Token outings occur without roles, relationships or 
contribution - no CPI timetable, no skill progression. 
3. Candour without proof. Assertions in files aren’t tied to observed practice or 
verifiable artefacts (two-party e-receipts, OSCE logs, calibration notes). 
4. Capability without supervision and renewal. Induction is classroom-heavy; 
coaching and field observation are thin; competence isn’t re-tested on a cycle. 
5. Paper training. Online-only modules, rubber-stamped bridging/RPL, and low-
rigour quizzes substitute for observed competence (no OSCEs, no EPAs, no 
supervised drills). 

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6. Thin syllabus and drift. Core safety and communication skills are absent or optional; 
providers back-fill with local habits; service delivery slides to “housekeeper role”, 
“screens-as-care” and call-the-ambulance/ police practice. 
7. Oversight without live verification. Ombudsman investigations and Public 
Trustee/Guardian decisions rely heavily on paperwork; mandates are fragmented; 
remedies are slow or non-binding; there is little routine “file-vs-field” testing to 
reconcile claims with practice. 
8. Guardianship over support. Broad or long-running substitute-decision orders are 
used where supported decision-making could work; thresholds and reviews vary; 
“best interests” can override will and preferences without structured reasoning 
(Reasons & Weighting). 
9. Role concentration and incentive mis-match. When one agency / individual holds 
both financial administration and guardianship, conflicts and delays can arise; fee-
funded administration and defensive risk settings prioritise asset protection over 
timely life improvements (transport, equipment, housing), dampening participation 
and prolonging dependency. 
10. Fragmented accountability. Multiple bodies (Tribunal, OPA/Guardian, 
Ombudsman, Public Trustee/Guardian, NDIS Commission) have overlapping but 
incomplete remits, creating gaps where responsibility dilutes and problems recycle. 
 
 
Problem Definition (Today) 
 
Person at the centre (lived reality and impacts) 
• Preventable crises go unnoticed. When the person isn’t consistently engaged - no 
regular check-ins, body cues read, or AAC used - early signs are missed (tooth 
pain/dental decay, constipation, dehydration, skin breakdown, medication side-
effects). Sentinel risks (choking/aspiration, seizure escalation, infection) aren’t 
anticipated, so avoidable ED presentations and hospitalisations follow. 
• Unheard in decisions. Plans are written about them, not with them; will and 
preferences aren’t recorded; consent/assent is assumed; AAC/interpretation is 
professed, but missing. 
• Latency misread as disinterest. Processing delay and cognitive fatigue look like 
“non-compliance”; conversations move on before meaning lands; penalties follow. 
• Environments that don’t fit. Noise, glare, smells, crowds and rushed routines trigger 
distress; “behaviours of concern” are untreated communication/sensory signals. 
• Safety assumed, not proved. Mealtime/IDDSI, seizure thresholds and medication 
changes are guessed at or reset in ED; they carry the risk of those guesses. 
• Role poverty. Few roles in ordinary places; CPI minutes are low; skills aren’t 
practised, so dependence grows. 
• Housekeeper drift. Support shifts prioritise cleaning/errands over community roles; 
CPI minutes flatline; the person becomes “a shift,” not a neighbour. 
• “Screens-as-care.” Devices substitute for presence and coaching; sleep, mood and 
motivation slide. 
• Paper without access. Reviews happen around them; no Plain English/Easy Read; 
they can’t see their own data or progress. 
• Safety by paperwork. Thick files, thin drills; the gap between what’s written and 
what shows up in the lounge room or at the bus stop. 

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• Isolation mistaken for stability. High time at home/on screens reads as “settled,” 
while skills stall and life shrinks. 
• Cultural identity sidelined. First Nations/CALD/Auslan needs aren’t planned for; no 
cultural plan or community anchors. 
• Dignity at risk. Intimate care without privacy, predictability or choice of 
carer/gender; revolving staff erodes trust. 
• Continuity broken. Many strangers, thin supervision, churn; “I am a shift, not a 
person.” 
• Health overshadowed. Pain, trauma, sleep and constipation are labelled “behaviour”; 
psychotropics become the default. 
• Sleep debt and health decline. Night vigilance, seizure anxiety, bowel/sleep 
disruption; both person at centre health quietly worsens. 
• Gate-kept supports. Delays in approvals (e.g., Public Trustee/Guardian and sole 
guardian decisions, plan changes) stall essentials - equipment, transport, housing 
tweaks - that enable everyday life. 
• Emergency default. Without low-arousal/AAC skills on roster, distress that could be 
de-escalated in place instead escalates to police/ED, compounding trauma and stigma. 
Families (lived reality and impacts) 
• Isolation mistaken for stability. High time at home/on screens reads as “settled,” 
while skills stall and life shrinks. 
• Over-protection → burnout. Rescue/control cycles arise without tools, switching 
support or respite; guilt follows when restraint/sedation occurs. 
• Low trust in the system. Retelling stories, fragmented services, slow/opaque 
decisions; complaints ping-pong between agencies. 
• Hidden cost of care. Lost work, reduced hours, superannuation hits; out-of-pocket 
spend on transport, consumables, repairs and short-notice cancellations. 
• Admin burden. Time on forms, portals and appeals displaces time in community; 
families become accidental case managers. 
• Gatekept essentials. Delays with Public Trustee/Guardian, insurers and equipment 
suppliers stall housing tweaks, transport and aids - blocking participation now. 
• Churn and thin supervision. New faces each week; little coaching from seniors; 
families re-teach basics (mealtime safety, communication) on every shift. 
• Sibling load and role reversal. Young people take on care tasks (“parentification”); 
sport/study/social lives compress; resentment and future-worry grow. 
• Sleep debt and health decline. Night vigilance, seizure anxiety, bowel/sleep 
disruption; carer health quietly worsens. 
• Relationship strain. Partners split roles (one earns, one cares) or split households; 
extended family withdraws under discomfort or fear. 
• Cultural/language mismatch. First Nations/CALD families face misread cues; 
interpreters and cultural plans are absent; mistrust deepens. 
• Fear of reprisal. Concerns that speaking up will reduce hours or trigger “hard to 
serve” labels; complaints feel risky. 
• Transport fatigue. Thin local options mean long travel for basics (GP, dental, 
therapy); missed work and school become normal. 
• Future dread. “Who when we’re gone?” - guardianship, housing, finances; no clear 
pathway to supported decision-making and ordinary roles. 
• Preventable crises go unnoticed. When the person isn’t consistently engaged - no 
regular check-ins, body cues read, or AAC used - early signs are missed (tooth 

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pain/dental decay, constipation, dehydration, skin breakdown, medication side-
effects). Sentinel risks (choking/aspiration, seizure escalation, infection) aren’t 
anticipated, so avoidable ED presentations and hospitalisations follow. 
• Emergency default. Without low-arousal/AAC skills on roster, distress that could be 
de-escalated in place instead escalates to police/ED, compounding trauma and stigma. 
• Moral injury. Asked to sign off on practices that don’t feel right (screens-as-care, 
routine restraint), eroding a sense of goodness and partnership. 
Frontline practice 
• Titles without competence. Generic “Direct Care” labels do not signal skill; 
supervision and observation are thin; renewal is rare. 
• Paper over practise. Long plans, little field coaching; documentation diverges from 
what happens in ordinary places. 
• Escalation without learning. Restraint minutes are not consistently time-kept; 72-
hour learning reviews and fade plans are inconsistent. 
Services and market 
• Weak quality signals. Families cannot see competence; good providers lack visible 
advantage; a minority game the gaps. 
• Switching friction. Exit/entry data are ad hoc; people feel “locked in”; coordination 
is not independent from provision. 
• Rural disadvantage. Thin workforce, limited interpreters/Auslan/AAC, long travel: 
parity is not real. 
Decision-making and oversight 
• File vs field contradictions. Tribunals/OPAs face partial, inconsistent evidence; 
reasons are hard to publish clearly. 
• Late verification. Issues surface after harm or payment; independent calibration 
(DSC) technique is scarce or not standardised. 
Data, privacy and integrity 
• After-the-fact checks. Claims paid before verification; anomalies reviewed late. 
• Incompatible systems. No minimum, open schemas; privacy reviews (DPIAs) are 
inconsistent; audit trails are fragile. 
• Public invisibility. No clear, trusted dashboards families can read; method notes are 
absent. 
Equity 
• First Nations partnership patchy. Cultural safety is often advisory, not embedded 
with decision rights. 
• Language access not guaranteed. Interpreter/Auslan/AAC support is inconsistent at 
critical moments (planning, reviews, hearings). 

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Problem statement (concise) 
 
Today’s system cannot reliably turn principle into daily practice. Proficiency is not signalled 
or renewed; safety does not always lead to learning; integrity is retroactive; decisions lack 
explainable reasons; equity depends on postcode; and families cannot see enough to choose 
or switch. The standards in this paper exist to close these gaps in the flow of work - not as 
extra paperwork. 
 
System drivers for change 
• Human rights and dignity. Least-restrictive by default; supported decision-making; 
visible reasons for decisions; family/guardian visibility where appropriate. 
• Quality of life and health. Presence and participation correlate with better wellbeing; 
iatrogenic harms (including medication and restraint) must be reduced. 
• Workforce reality. Turnover, variable skill and limited supervision require a 
recognised pathway with observed practice and renewal. 
• Economics and stewardship. Preventable harms are costly; pre-claim controls and 
visible quality signals reduce waste and rework. 
• Public trust. Dashboards and auditable artefacts make progress legible to families, 
providers and ministers. 
• Implementation window. Early-supports reforms and procurement cycles allow 
pilot-first delivery using existing powers. 
 
 
What We Lost and Must Restore - Human Outcomes, Dignity and Social Value 
 
Outcomes that matter (what changes in real life) 
• Belonging & roles: more time in ordinary places; more roles (volunteer/trainee/paid); 
stronger relationships. 
• Autonomy & safety: supported decisions; least-restrictive responses; restraint 
minutes trend down; learning reviews trend up. 
• Health continuity: GP/ED hand-backs completed; meds reconciled; fewer avoidable 
re-presentations. 
• Family confidence: clear weekly plans; lower invisible labour; switching friction 
resolved. 
• Equity realised: interpreter/Auslan/AAC used at key moments; First Nations 
partnership active; rural parity via micro-hubs. 
How we will measure it (linked to dashboards) 
• Presence/participation minutes; role counts; independence step-ups. 
• Restrictive minutes/1,000 hours; 72-hour review compliance; fade-plan success. 
• Health: reconciliation ≤72h; avoidable ED ≤7/30 days. 
• Confidence: family index; time-to-switch; week-1 completion. 
• Equity: interpreter timeliness; micro-hub coverage; rural vs metro parity. 
[See Data, Dashboards and Privacy  -  Performance, KPIs & Public Dashboards.] 

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Social value lens (why this is worth doing) - lost / restore / test 
Lives grow when ordinary places, roles and relationships grow. These outcomes are not 
“soft” - they are the point of the system and the best predictors of long-run stability, safety 
and value. 
Presence in ordinary places  
Lost: everyday roles were replaced by programs and screens. 
Restore: measurable minutes in real settings and roles (volunteer/trainee/paid), with natural 
supports and prompt-fading. 
Test: sustained ↑ in presence/participation minutes and independence steps. 
Supported decision-making and dignity of risk 
Lost: risk was avoided by shrinking life. 
Restore: least-restrictive by default, with proportionate safeguards and real choices. 
Test: 72-hour review compliance and fade-plan success trending up; seclusion/chemical 
restraint trending down. 
Candour by design (truth in the flow) 
Lost: truth was reconstructed later, with poor memory and poor signals. 
Restore: two-party e-receipts, roster-to-claim cross-checks, immutable logs - so integrity is 
built in, not inspected in. 
Test: e-receipt coverage/timeliness ≥ thresholds; exception ageing ↓; sanctions recurrence ↓. 
Independent verification and published reasons 
Lost: contested matters recycled; reasons were hard to follow. 
Restore: DSC file-vs-field calibration, Reasons & Weighting + Contradiction Matrix, and 
plain-English publication. 
Test: median DSC turnaround ≤ 21 days; publication timeliness ↑; appeal/overturn rate stable 
or ↓. 
Proficient, supervised frontline (IDC) 
Lost: competence signalled by position title, not observed practice. 
Restore: IDC pathway with supervised practise, EPAs, OSCEs and renewal; tele-OSCEs and 
micro-hubs for rural parity. 
Test: OSCE pass and renewal on time; supervision throughput; turnover ↓. 
Equity and local partnership 
Lost: cultural safety and language access were optional add-ons. 
Restore: paid First Nations MOUs, interpreter/Auslan/AAC as defaults, rural micro-hubs and 
scholarships. 
Test: interpreter timeliness; micro-hub coverage; equity gaps in outcomes closing. 
Public accountability that helps, not harms 

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Lost: either opacity or naming-and-shaming without method. 
Restore: de-identified public tiles with suppression rules + family view for person-level truth; 
method notes every quarter. 
Test: on-time releases; suppression accuracy; family sign-ins/usefulness. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

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NDIS  -  Interface & Reform Alignment (2025) 
Why this matters (and why it hasn’t worked) 
The NDIS is the primary public funder touching the lives of many people with cognitive 
disability. Its original promise - individual budgets, choice and control - has been blunted by 
variable market quality, thin navigation, uneven access to mainstream services, and weak 
truth-by-design controls. The Disability Royal Commission documented violence, abuse, 
neglect and exploitation across systems, underscoring that safeguards must be designed-in, 
not inspected-in later. 
Fast take (read this first) 
• The 2023 Independent NDIS Review recommended a five-year blueprint including: a 
Navigator function (replacing Support Coordination/LAC), Foundational Supports 
(outside individual NDIS plans), tighter provider regulation, and better interfaces with 
mainstream services.  
• National Cabinet (Dec 2023) agreed in principle to jointly design and fund 
Foundational Supports with states and territories (50:50), with detailed design work 
continuing through 2024-25.  
• The NDIS Amendment (Getting the NDIS Back on Track No. 1) Act 2024 
commenced 3 Oct 2024, enabling new rules to tighten scheme operation and 
quality/safeguards.  
• The NDIS Commission has moved toward mandatory registration for Support 
Coordination, SIL, and Platform providers (consultation concluded; implementation 
approach in development).  
• In 2025, the Commonwealth announced a “Thriving Kids” foundational-supports 
program intended to better serve children with mild to moderate developmental needs 
outside the NDIS (timelines and scope still maturing).  
Bottom line for this paper: plan for Navigators + Foundational Supports to reshape the front 
door, tighten provider regulation, and expect rules to keep shifting through 2026-27. Align 
the paper’s IDC/DSC/Two-Key architecture so it’s compatible regardless of where support is 
funded. 
What’s changing (status 2025) 
1. Navigators (replace Support Coordinators/LACs). 
The Review’s blueprint reframes navigation as a universal function (not limited to 
NDIS participants), with specialist streams for complex cohorts. Government 
communications and sector guidance point to phased trials/pilots before wider rollout; 
current Support Coordination persists during transition.  
2. Foundational Supports (outside NDIS plans). 
Governments are designing a nationally coherent layer (general + targeted) to reduce 
the “NDIS or nothing” cliff, with joint funding and governance to be settled and 
phased. This will shift some demand away from individual NDIS packages and 
requires local interfaces to health, education and community services.  
3. Legislative/rules platform (from Oct 2024). 
The Getting the NDIS Back on Track No. 1 Act 2024 provides head-powers for new 

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rules covering access, plan settings, market conduct and safeguards. Expect 
subordinate instruments and operational guidance to iterate.  
4. Mandatory registration (selected provider classes). 
NDIS Commission policy direction is to mandate registration (beginning with SIL, 
Support Coordination and platforms) with risk-proportionate regulation; detailed 
transition design has been consulted on and is pending implementation phases.  
5. Royal Commission follow-through. 
The DRC’s 222 recommendations reinforce inclusive education, stronger safeguards, 
and real accountability - principles this paper operationalises via Two-Key decisions, 
DSC calibration and publication tiles. 
Pros (if implemented well) 
• Less fragmentation, more fairness. Navigators + Foundational Supports reduce the 
“find-it-yourself” burden and connect people to mainstream/community services 
earlier. 
• Higher baseline safety. Mandatory registration narrows grey markets and enables 
proportionate oversight (complaints, investigations, sanctions) for classes that have 
been variable to date. 
• Clearer legislative footing. The 2024 Act supports tighter rules on access, plan design 
and provider conduct, allowing faster correction of rorts and poor practice.  
• Better fit for children. Dedicated foundational programs (e.g., Thriving Kids) may 
reduce inappropriate reliance on NDIS for developmental needs, if quality and 
coverage are real.  
Cons / risks (to watch and design around) 
• Transition turbulence. If Navigator pilots, rules and funding arrive out-of-sequence, 
participants may see reduced Support Coordination before Navigator coverage exists. 
(Mitigation below.) 
• Coverage gaps in Foundational Supports. National agreements don’t automatically 
translate to local service availability; states need time, workforce and commissioning 
competence.  
• Registration ≠ quality by itself. Mandating registration can drive paperwork without 
lifting practice unless supervision, calibration and publication tiles make quality 
visible.  
• Cost-containment pressure. Fiscal targets may create hidden rationing (fewer plan 
reviews; slower approvals) unless Right-to-Reasons and dashboards expose drift 
What this paper adds (runnable interfaces) 
A. Navigator ⇄ IDC handshake (no wrong door). 
• Any Navigator touchpoint triggers the IDC Offer of Communication Access (OP-01), 
Plain-English Plan Summary, and - where risk or complexity is flagged - DSC triage 
for file-vs-field checks. 
• Navigators adopt our Two-Key convention for consequential decisions they influence 
(e.g., SIL/SDA moves, psychotropic initiation), logging Reasons & Weighting and a 
short Will & Preferences note. 

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B. Foundational Supports bridge. 
• Local agencies map Foundational Supports to our Service Model Standards: weekly 
community schedule (L-tiles), participation measures (CPI), and interpreter/AAC 
triggers (N-pack). 
• When a need falls outside NDIS plans, we still require e-receipt + Owner Matrix; the 
funder changes, the integrity rules do not. 
C. Mandatory registration alignment. 
• Providers in scope (SIL, Support Coordination/platforms → Navigators when stood-
up) must show: 
1. Roster↔Claim cross-checks, 
2. Contradiction Matrix resolution on disputes, 
3. 72-hour review after Tier-0 events, and 
4. publication-ready tiles with suppression rules.  
D. Royal Commission follow-through. 
• Embed DRC principles through Least-Restrictive by default, Two-Key for liberty-
reducing actions, and DSC calibration quarterly with public quality summaries.  
 
Risks & mitigations (NDIS-specific) 
Risk What it looks like Mitigation (this paper) 
SC funding reduced 
before Navigator 
coverage 
Participants lose 
coordination; 
families carry admin 
Stop-rule: no removal of SC unless Navigator 
availability is confirmed & warm handover completed; 
Tile: navigator_coverage_rate.  
Foundational 
Supports thin on the 
ground 
“Referred out” with 
nowhere to go 
Owner Matrix: assign commissioning owner + 
timeframe; Tile: foundational_access_time.  
Registration adds 
paperwork, not 
practice 
Box-ticking without 
field change 
DSC calibration (file-vs-field), OSCE spot checks, 
Sanctions ladder tied to publishable evidence. 
Cost-pressure 
suppresses reviews 
Long gaps between 
plan changes 
Right-to-Reasons twin for deferred decisions; Tile: 
time_to_decision & reviews_within_service_guarantee. 
 
Measures & public tiles 
Minimum payload keys for each published point: source, period, last_updated, definition, 
suppression_applied. 

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1. Navigator Coverage (navigator_coverage_rate) 
Numerator: participants with an assigned Navigator (or confirmed warm handover). 
Denominator: participants meeting risk/complexity criteria. 
2. Foundational Access Time (foundational_access_time) 
Median days from referral to first attended foundational support. 
3. Registration Progress (mandatory_registration_uptake_sc_sil_platform) 
% of in-scope providers transitioned to the new registration class. 
4. Right-to-Reasons On-Time (r2r_on_time_rate) 
% of NDIS-linked decisions issued with a Plain-English reasons note within service 
guarantees. 
5. Integrity Pairing (two_key_coverage_ndis_decisions) 
% of consequential NDIS-linked decisions with Two-Key + Reasons & Weighting 
logged. 
(Apply Appendix S suppression/privacy rules to all tiles.) 
 
Switching & safeguards (NDIS events) 
• SDA/SIL changes, restrictive-practice authorisations, high-value AT, interstate moves 
→ require Two-Key and R&W; log Tier-0/Tier-1 triggers; run a 72-hour learning 
review after any crisis admission or PRN psychotropic escalation. 
• Children (Thriving Kids interface). Use the same guardrails (Plain-English reasons, 
interpreter/AAC, publication tiles) whether the support is inside NDIS or via a 
foundational program.  
 
Consistent with government directions 
• This white paper’s model is NDIS-compatible. As Navigators and Foundational 
Supports roll out, we will not let coverage gaps emerge. Where a support moves 
outside the NDIS, integrity, safety and reasons move with it. 
• This white paper strongly supports National Cabinet’s direction on Foundational 
Supports and the Commission’s move to mandatory registration for higher-risk 
provider classes, paired with publishable dashboards. 
• Appendix S (tiles & suppression), 
• Appendix G/H/I/J (Sanctions, R&W, Contradiction Matrix, IRC), 
• Appendix AO (IDC equivalency/bridges for Navigators), 
• Appendix AG (Candour by Template for tribunals/OPA). 
 
 
 

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Standards Overview (how all pieces fit) 
 
The standards map 
 
This paper specifies an end-to-end system: each standard has a purpose, minimum 
requirements, measurable indicators, and publishable artefacts. Use this map as the quick 
index; details live in the named sections. 
Workforce Standard  -  Integrated Disability Clinician (IDC) 
Objective. Professionalise the frontline so skill, judgement and ethics are observable and 
renewable. 
 
What changes in practice. “Direct Care” roles transition to the IDC pathway with mapped 
curriculum, supervised practise, OSCEs and 3-year renewal. 
 
Minimum requirements. Curriculum → supervised hours → EPAs/portfolio → OSCE pass 
→ renewal; quarterly peer calibration; de-rostering rules. 
 
Key metrics. IDC licence/renewal rates; OSCE pass rates; supervision throughput; peer-
review variance. 
 
Primary tools/artefacts. Curriculum map; OSCE stations & rubrics; EPA logbook; licensure 
register; peer-review protocol. 
 
Appendix links. Equivalency Matrix (legacy roles → IDC); Pilot supervision templates. 
 
 
Safety & Restrictive Practices Standard 
 
Objective. Make least-restrictive the default and convert every restraint incident into learning. 
 
What changes in practice. Restraint hierarchy with timekeeping; 72-hour learning review; 
mandatory fade plans; hospital/ED handover & medication reconciliation. 
 
Minimum requirements. Log minutes; conduct 72-hour reviews; record alternatives tried; 
maintain and monitor fade plan. 
 
Key metrics. Restrictive minutes/1,000 support hours; 72-hour review compliance; fade-plan 
success rate; med reconciliation completion. 
 
Primary tools/artefacts. Restraint hierarchy; timekeeping template; 72-hour review form; 
fade-plan template; handover checklist. 
 
Appendix links. Restraint Hierarchy & Timekeeping Standard; Handover & Reconciliation 
pack. 
 

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Truth-by-Design Standard 
 
Objective. Move integrity from after-the-fact audits to built-in controls. 
 
What changes in practice. Two-party e-receipts; roster-to-claim cross-checks before payment; 
proportionate sanctions ladder with publication rules. 
 
Minimum requirements. E-receipt coverage; exceptions triage; corrective actions with time-
bounds; publication cadence. 
 
Key metrics. E-receipt match rate; exceptions rate & time-to-resolution; sanctions ladder 
utilisation. 
 
Primary tools/artefacts. E-receipt schema; cross-check rules; exception queue; sanctions 
ladder. 
 
Appendix links. Minimum Two-Party E-Receipt JSON Schema; Publication & Suppression 
Rules. 
 
Independent Verification Standard - Decision Support Consultant (DSC) 
Objective. Ensure contested/high-risk matters have neutral file-vs-field calibration and 
publishable reasons. 
 
What changes in practice. Decision Support Consultant (DSC) engaged with structured 
artefacts; tribunals/OPAs adopt Reasons & Weighting and Contradiction Matrix. 
 
Minimum requirements. DSC assignment triggers; field observation; artefacts lodged; plain-
English reasons published (with privacy safeguards). 
 
Key metrics. DSC turnaround; calibration variance (file vs field); publication timeliness; re-
work/appeal rate. 
 
Primary tools/artefacts. Reasons & Weighting template; Contradiction Matrix; DSC field 
note; Independent-Reasoning Certificate. 
 
Appendix links. Tribunal/OPA tool pack; DSC operating procedure. 
 
 
Two-Key Guardianship (No one decides alone) 
 
Objective. End sole-guardian decision-making for consequential matters; require two 
independent keys (co-sign) or MPG quorum, with a short Reasons & Weighting and a will-
and-preferences record for every in-scope decision. 
What changes in practice. Co-sign (or MPG quorum) before acting on high-stakes decisions; 
Tier-0 emergency path (make safe) logged ≤24h with a 72-hour learning review; use the 
Independent Pairing Pool (IPP) if a second guardian is unavailable/recused (tele-co-sign 

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allowed); independence/rotation checks recorded; engage DSC where disputed, delayed or 
liberty-reducing. 
Minimum requirements. Decision falls within defined classes (life, liberty, health, home, 
finances, close relationships) → Two-Key/MPG applied; R&W short form + will-and-
preferences (with SDM/BIWP methods noted); identity and independence check for both 
keys; IPP pairing within 72h where needed; Tier-0 log and 72-hour review if emergency 
used; privacy-safe publication (n<5 suppression); records filed to case pack and visible in 
family view. 
Key metrics. Two-key coverage (% of in-scope decisions with valid co-sign/quorum); 
median/p95 time-to-co-sign (hours); Tier-0 exception rate (per 100 decisions); 72-hour 
review coverage (% of Tier-0); rotation compliance (% non-repeating pairs within window); 
DSC escalation rate; equity lens gaps (First Nations, CALD, rural/remote, gender, age 
bands). 
Primary tools/artefacts. Two-Key Decision Record (R&W short form + will-and-
preferences); Independence & Conflict Check (pairing/rotation ledger); Tier-0 Log & 72-
Hour Review; DSC Calibration Memo (Two-Key); IPP pairing request/response; Publication 
Note (de-identified). 
Appendix links. Tribunal Practice Note  -  Two-Key; OPA/OPG Investigations Code 
Addendum; Procurement Direction & IPP SLA; Dashboard Tile Specifications  -  Two-Key; 
Talking Points & Q&A. (Cross-refs: Appendix B  -  72-Hour Review; Appendix H  -  
Reasons & Weighting; Appendix I  -  Contradiction Matrix; Appendix J  -  Independent-
Reasoning Certificate.) 
 
 
Service Model Standards (life in community) 
Objective. Replace “screens-as-care” with presence and participation in ordinary places. 
 
What changes in practice. Weekly goals emphasise real-world roles; coordination 
independent from provision; switching is easy and supported. 
 
Minimum requirements. Community schedule; role/relationship targets; switching protocol & 
time-limits; accessible plans (Plain English/Easy Read). 
 
Key metrics. Minutes in ordinary places; goal attainment; switching friction (time/cost); 
family confidence index. 
 
Primary tools/artefacts. Community presence tracker; accessible plan templates; switching 
checklist. 
 
Appendix links. Family Toolkit & Easy Read samples; Switching Protocol. 
 
 

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Equity, First Nations Partnership and Access 
 
Objective. Ensure standards hold everywhere and for everyone. 
 
What changes in practice. First Nations partnership; CALD/Auslan access; rural micro-hubs, 
tele-OSCEs and scholarships. 
 
Minimum requirements. Partnership MOUs; interpreter availability; rural enablement plans. 
 
Key metrics. Interpreter utilisation; micro-hub coverage; rural OSCE completion; equity gap 
closure. 
 
Primary tools/artefacts. Partnership framework; interpreter booking SOP; micro-hub pack; 
scholarship terms. 
 
Appendix links. Equity Delivery Notes; Rural Enablement Kit. 
 
 
Data, Dashboards and Privacy 
 
Objective. Make progress legible while protecting people. 
 
What changes in practice. Open minimum schemas; role-based access; suppression rules; 
immutable logs; public dashboard tiles + family view. 
 
Minimum requirements. DPIAs for all flows; schema conformance; publication cadence. 
 
Key metrics. Data completeness; suppression accuracy; dashboard uptime; privacy incidents 
(zero tolerance). 
 
Primary tools/artefacts. DPIA template; schema specs; dashboard tiles; audit log spec. 
 
Appendix links. DPIA Template; Dashboard Tiles & Suppression Rules; E-receipt schema. 
 
 
Implementation Roadmap (Switch-On Order) 
 
Objective. Deliver quickly, safely, and at manageable scale. 
 
What changes in practice. Pilot → verify → publish → scale with go/no-go gates; leverage 
existing powers (practice notes, procurement, program rules). 
 
Minimum requirements. Pilot criteria; QA gates; privacy/AI conformance; rural inclusion. 
 
Key metrics. Milestone hit-rate; QA pass-rate; time-to-publish; pilot→scale throughput. 
 
Primary tools/artefacts. Switch-on checklist; QA gate pack; pilot evaluation plan. 
 
Appendix links. Pilot Evaluation Plan; Switch-On Checklist. 

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Finance & ROI Case 
 
Purpose. Upgrade the “12-24 Month ROI Plan” into a systems-grade program that integrates 
policy, economics, clinical governance, market design, behavioural science, data/AI, law, 
anthropology and ethics - so choices are coherent and trade-offs transparent. 
Method. We apply ten steps that support a walk-with cadence (draft → test → measure → 
adjust): 
1 Problem framing 
2 First principles 
3 Human nature and behaviour 
4 Allocation and incentives 
5 Power and conflicts 
6 Innovation and learning 
7 Crisis and adaptation 
8 Implementation 
9 Stress tests 
10 Final integration 
 
Objective. Align money with outcomes and avoided harm. 
 
What changes in practice. Track avoided hospital/ED events, reduced re-work, market quality 
signals; publish ROI workbook outputs. 
 
Minimum requirements. Baselines; counterfactual assumptions; quarterly ROI updates. 
 
Key metrics. Avoided harm value; unit-cost shifts; sanctions vs corrective actions; provider 
quality mix. 
 
Primary tools/artefacts. ROI workbook; finance brief; publication schedule. 
 
Appendix links. Finance Brief; ROI Workbook Notes. 
 
 
 

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Governance, Assurance and Risk 
 
Objective. Clarify ownership, escalation and proportionate accountability. 
 
What changes in practice. Named owners per standard; sanctions ladder; red-team stress 
tests; risk register with triggers. 
 
Minimum requirements. Owner matrix; escalation time-limits; quarterly stress tests. 
 
Key metrics. Issue time-to-close; stress-test findings closed; sanctions ladder consistency. 
 
Primary tools/artefacts. Owner matrix; escalation playbook; stress-test protocol; risk register. 
 
Appendix links. Assurance Pack; Stress-Test Protocol. 
 
Evaluation & Continuous Learning 
 
Objective. Turn evidence into improvement, not blame. 
What changes in practice. Quarterly peer reviews; double-loop learning; sunset/refresh rules 
for standards. 
 
Minimum requirements. Peer-review sample & rubric; publish quality summaries; 
improvement actions tracked. 
 
• Key metrics. Calibration variance; improvement closure rate; standard refresh 
cadence. 
 
• Primary tools/artefacts. Peer-review rubric; improvement log; refresh calendar. 
 
• Appendix links. Calibration Protocol; Publication Templates. 
 
 
Assurance spine (from indicator → dashboard → publication) 
• Indicators. A compact set of measures power all dashboards: IDC licence & OSCE 
pass; restrictive minutes/1,000 hours; 72-hour review compliance; fade-plan success; 
e-receipt coverage; exceptions rate; DSC turnaround & publication timeliness; 
minutes in ordinary places; switching friction; equity coverage; privacy incidents 
(target: zero). 
• Data sources. IDC register; timekeeping logs; e-receipt store; roster/claim system; 
DSC artefacts; community presence tracker; interpreter bookings; audit logs. 
• Publication. Quarterly public tiles (de-identified, suppression rules applied) plus 
family-view details; immutable audit logs; versioned release notes. 
• Quality loop. Every publication triggers: (1) peer calibration, (2) improvement 
actions, (3) refresh decisions. 
[See Data, Dashboards and Privacy; Evaluation & Continuous Learning.] 

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Switching costs and risk controls 
• Separation of roles. Coordination independent from provision to reduce conflicts. 
• Easy switching. Standardised exit/entry data set; time-limits; fee transparency; 
switching support. 
• Sanctions ladder. Proportionate, transparent consequences with published signals to 
shift the market toward competence. 
• Rural parity. Tele-OSCEs, micro-hubs, scholarships maintain regional access during 
transitions. 
• Stress tests. Red-team scenarios (e.g., provider failure, data incident, restraint spike) 
with rehearsed playbooks. 
[See Service Model Standards (life in community); Governance, Assurance and Risk; 
Equity, First Nations Partnership and Access.] 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 68 
 
Workforce Standard  -  Integrated Disability Clinician (IDC) 
 
National IDC‑Prep Standard (TAFE, University, RN‑integrated, Bridging) 
 
Purpose & scope 
 
Professionalise the frontline so proficiency, judgement and ethics are visible, renewable and 
portable across settings. Replaces generic “Direct Care” with a structured pathway that 
includes mapped curriculum, supervised practise, observed competence (OSCEs/EPAs) and 
periodic renewal. Applies to all paid frontline roles delivering day‑to‑day supports in home, 
community, education, health and justice interfaces. 
 
Role definition (what an IDC is and is not) 
 
• IDC is a person‑first practitioner who plans, delivers and adapts supports in ordinary 
places, integrates allied inputs, and works least‑restrictive by default with dignity of risk. 
• IDC is not a proxy nurse/clinician unless separately credentialled; IDC defers to clinical 
prescribers for scope‑limited tasks and focuses on safe everyday practice, skill‑building 
and participation. 
• Levels: Foundation → Proficient → Advanced (supervisor/educator); level sets 
supervision ratios, OSCE complexity and portfolio expectations. 
 
Protected title, statutory levers & anti‑gaming controls 
 
• Protected title: “Integrated Disability Clinician”. Provider registration and price eligibility 
link to IDC‑accredited staff. 
• RTO (ASQA) gate: IDC‑Prep Diploma uses the national curriculum and assessment bank 
(OSCEs, EPAs, supervised practice). No coalface scope taught/assessed below this 
standard. 
• University (TEQSA) gate: Programs claiming IDC outcomes map to the same assessment 
gates (OSCE bank, EPAs, supervision, documentation integrity). 
• Funding levers: VET Student Loans / FEE‑HELP and public subsidies flow only to 
programs implementing this Standard; procurement mandates IDC ratios by role. 
• Assessment integrity: National OSCE bank; external examiners; randomised variants; 
identity checks; item analytics; cohort outcomes published. 
• RPL boundary: Safety‑critical OSCEs/EPAs are never waived; bridging is the route. 
• Sunset: Cert III/IV not valid for coalface scope from the transition date (retained only for 
non‑clinical support stacks). 
• Paediatrics & rural parity: IDC‑Paeds modules across TAFE/University; rural 
block‑release intensives; tele‑assessments; satellite OSCE hubs recognised as equivalent. 
• Publication: Campus‑level results (OSCE pass, placement completion, early‑career safety 
indicators) reported quarterly. 
 
Competency framework (domains) 
 
• Person‑first practice & rights: supported decision‑making; least‑restrictive tests; fade 
planning. 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 69 
 
• Communication & behaviour support: AAC, de‑escalation, function‑based support, 
trigger mapping. 
• Health & safety basics: medication handover/reconciliation; risk assessment; infection 
control; safe transport. 
• Community presence & participation: goal‑setting, graded exposure, role development, 
natural supports. 
• Documentation & candour: contemporaneous notes, two‑party e‑receipts, 
incident/learning reviews. 
• Cultural safety & equity: First Nations partnership, CALD/Auslan access, 
trauma‑informed practice. 
• Systems & data: dashboards, privacy‑by‑design, roster‑to‑claim integrity, improvement 
cycles. 
• Professionalism: ethics, boundaries, reflective practice, supervision, whistleblowing. 
 
Education & pathways (TAFE, University, RN‑integrated, Bridging) 
 
A. IDC‑Prep (TAFE/VET Diploma or assessed equivalent). Must use the national 
curriculum/assessment bank and the ‘higher‑of’ hours and gate rules below. 
 
B. University programs. Degrees claiming IDC outcomes must meet the same 
OSCE/EPAs/supervision gates and documentation‑integrity expectations as IDC‑Prep. 
 
C. RN‑integrated pathway (Year‑2 exit option). Structure: RN Y1-Y2 with disability 
embedded; exit at end‑Y2 awards IDC (workforce‑ready). Year‑3 completes RN. IDC 
graduates returning within 5 years receive credit for Y1-Y2 nursing components. 
 
• Placements (higher‑of): 600-700 hours total blended across acute hospital (250-300h), 
SIL/SDA (250-300h), community clinic/allied (100h), optional DSC tribunal observation 
(8-16h). 
 
D. Bridging for current workforce (RA‑IDCP) & existing RNs → IDC. 
 
• RA‑IDCP (incumbents): part‑time 12-18 months while employed; core modules (A&P for 
disability, medication safety, PBS & law, documentation, SDM, de‑escalation/emergency, 
interdisciplinary handover); 240-300h supervised practise; assessments include written 
exams, OSCEs, observed practice, portfolio. 
• Existing Registered Nurses → IDC (on‑ramp): credit for RN content; gap‑modules in 
AAC, PBS, community presence/CPI, documentation integrity, tribunals & candour tools, 
mealtime/IDDSI, seizure protocols in disability contexts; 160-240h IDC‑context 
supervised practice; baseline OSCE set + ≥4 EPAs; portfolio artefacts. 
 
Curriculum map, supervised practise & CPD (higher‑of applied) 
 
Where prior instruments differ (A_DSC_IDC_Reform_Blueprint; 
B_DSC_IDC_Policy_and_Legislative_Pack; template & crosswalk series), this standard 
adopts a conservative higher‑of envelope to protect safety and lift practice. 
 
• Structured learning across all domains: 240 hours  -  Scenario‑based; spaced rehearsal; 
assessment‑ready artefacts. 

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• Applied micro‑modules (context variants): 120 hours  -  Rural/remote; education liaison; 
justice interfaces; mealtime/IDDSI deep‑dive. 
• Equity & cultural safety modules: 40 hours  -  First Nations partnership, 
interpreters/Auslan, AAC and accessibility. 
• Simulation & drills (safety stations): 40 hours  -  Mealtime/choking; seizure; 
de‑escalation; medication handover. 
• Assessment preparation: 20 hours  -  OSCE/EPAs rehearsal; documentation integrity 
exemplar. 
 
Supervised Practice and Observation 
 
• Supervised hours (minimum 400) under an Advanced IDC or equivalent; ratio caps by 
risk and setting. 
• Field observations (minimum 20) across typical and high‑stress interactions; ≥4 by an 
external supervisor (not line manager). 
• Documentation integrity checks (minimum 6) linking file notes to observed practice 
(candour). 
• CPD & renewal: renewal every 3 years with ≥60h CPD/year (≥12h equity); mini‑OSCE 
or workplace assessment; candour check; recency ≥900 frontline hours/3y. 
 
EPAs (Entrustable Professional Activities) 
 
• EPA‑1: Run a person‑first planning conversation with supported decision‑making and 
accessible materials. 
• EPA‑2: Deliver a community session that builds presence and participation (graded task + 
debrief). 
• EPA‑3: Manage a low‑to‑moderate escalation using least‑restrictive options; record 
timekeeping if restraint is used; initiate the 72‑hour learning review. 
• EPA‑4: Complete a safe medication handover/reconciliation with clear responsibility 
lines. 
• EPA‑5: Produce a clean documentation pack (notes → plan → dashboard inputs) 
including a two‑party e‑receipt where applicable. 
 
Each EPA is signed off after at least two observed completions without critical error. 
 
OSCE (Objective Structured Clinical Examination) 
• Stations (6-8): person‑first planning; AAC & communication; community role‑building; 
de‑escalation & rights testing; documentation & e‑receipt; privacy & DPIA scenarios; 
rural problem‑solving. 
• Format: 10-12 minutes per station + 3-5 minute examiner debrief; two examiners across 
the circuit to reduce bias. 
• Standard setting: borderline regression or equivalent; annual calibration using 
double‑rated videos; inter‑rater reliability published. 
• Accessibility: candidates may request reasonable adjustments; competence standard 
remains unchanged. 
 
Portfolio and renewal cycle 
 

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• Initial award: curriculum + supervised practice + EPA sign‑offs + OSCE pass. 
• Renewal every 3 years: ≥60 hours CPD/year (≥12h equity); two refreshed observations; 
one mini‑OSCE (3 stations) or equivalent workplace assessment; candour check 
(file‑vs‑field sample). 
• Recency of practise: minimum 900 hours frontline practise over the renewal period (or 
equivalent with supervision). 
 
Equivalency & bridging (legacy roles → IDC / licence‑aligned roles) 
 
• RPL pathways include: Support Worker, Education Support, Mental Health Support, 
Allied Health Assistant, Enrolled/Registered Nurse (non‑IDC tasks remain in clinical 
scope), Behaviour Support Practitioner. 
• Bridging bundles: map gaps per domain; assign micro‑modules, supervised observations 
and targeted OSCE stations. 
• Expiry of legacy titles: generic “Direct Care” titles sunset within 18 months (regionally 
staged where rural parity requires). 
• Grandparenting: time‑limited (≤12 months) conditional licence with supervision and 
mandatory bridging plan. 
• Outcomes rubric: PASS / BRIDGE / DEFER / FAIL; safety‑critical gates are 
non‑negotiable. 
 
Role-clean mapping - specific (titles → licence) 
 
COORD (Navigation & Adjacent) and OPS (Operational/Entry) classes defined so legacy 
titles move into explicit licence lines with independence-from-provision and no scope creep. 
 
• COORD must pass OSCE/EPAs for conflict screen, R&W drafting, plain-English 
explanations, interpreter/AAC use, escalation to DSC. 
• OPS must pass intake gateway OSCE (eligibility triage, warm handover, e-receipt 
issuance) and “records you can publish.” 
 
Safety gates that RPL cannot waive. 
 
• Dysphagia/IDDSI, seizure response, medication stewardship (psychotropics), 
restrictive-practice governance, PBS fidelity, and documentation integrity = must-
pass OSCEs/EPAs for anyone with coal-face scope. 
 
Supervised practice bands by legacy stream. 
 
• Support Coordinator → COORD: 160-240h supervised; 5 OSCEs; 4 EPAs; portfolio 
+ audit. 
• Behaviour Support Practitioner: 240-360h; 6 OSCEs; 5 EPAs; fidelity audits. 
• House/SIL Coordinator / House Manager (OPS/IDC-lead interface): 200-300h; 6 
OSCEs; 5 EPAs; IDDSI + risk register. 
• Plan Manager (Adjacent): 120-200h; 4 OSCEs; 4 EPAs; audit pack. 
• Practice/Quality Manager: 240-320h; 5 OSCEs; 5 EPAs; calibration/QI packs. 
 
RN on-ramp and incumbent bridging. 
 

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• RN → IDC: credit core nursing; 160-240h IDC-context supervised practise; baseline 
OSCE set + ≥4 EPAs + portfolio. 
• RA-IDCP (incumbents): part-time 12-18 months, core modules (A&P for disability, 
meds safety, PBS & law, documentation, SDM, de-escalation/emergency, 
interdisciplinary handover) + 240-300h supervised practise. 
 
Rural & regional enablement 
 
• Micro‑hubs: shared supervision pools across small providers; rotating Advanced IDC 
educators; travel funding rules. 
• Tele‑OSCEs: secure video OSCEs for defined stations; at least two stations must be 
in‑person during the renewal period. 
• Scholarships & backfill: targeted funding to prevent workforce shrinkage during 
training/assessment windows. 
• Interpreter pool & outreach tied to micro‑hubs with minimum service levels. 
 
Pricing, wage ladders & incentives (alignment) 
 
• Provider eligibility to claim IDC items requires ≥70% of designated‑role hours by 
certified IDCs (rising to 100% by T+24 months). 
• Outcome‑linked payments (QPIP): 2-3% pool returned as bonuses when 
safety/participation and integrity metrics improve (risk‑adjusted; anti‑gaming controls 
specified). 
• Wage benchmarks (signal only; jurisdictional bargaining applies): IDC $95k-$110k (+ 
penalties) 
• Scholarships & bonded placements prioritise rural, paediatrics and shortage roles; funded 
backfill during training/assessment windows. 
 
Documentation & artefacts (publishable or auditable) 
 
• Curriculum & assessment blueprint; OSCE station bank & rubrics; EPA logbook 
templates. 
• Supervision plan & observation rubrics; documentation‑integrity checklist. 
• Licensure register (public quality‑signal fields only); renewal‑status tiles for dashboards. 
• Equity compliance pack (interpreter usage, cultural safety engagements). 
 
Metrics & indicators (for dashboards) 
 
• Capability: IDC licence rate; OSCE pass rate; EPA completion rate; supervision 
throughput; peer‑review variance. 
• Equity: interpreter utilisation; cultural safety engagements; rural micro‑hub coverage; 
tele‑OSCE completion. 
• Safety linkages: reduction in restrictive minutes/1,000 hours; 72‑hour review compliance 
where IDC is lead/participant. 
• Integrity: documentation candour match (file‑vs‑field); e‑receipt coverage for IDC‑led 
sessions. 
 

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Governance & licensure 
 
• Owner: Workforce Standards Authority (or designated commissioner). 
• Registers: central licence register with public‑facing quality fields; private fields 
restricted to regulators. 
• Calibration: quarterly blind peer‑reviews; examiner moderation; variant analysis across 
regions. 
• Sanctions ladder: remediation → undertakings → administrative fines → procurement 
debarment → publication. 
• De‑rostering: triggered by failed renewal, integrity breaches, or critical incident findings; 
linked to the Sanctions Ladder. 
• Named supervisor, complexity caps, 72-hour learning reviews after Tier-0 events, 
quarterly DSC calibration (file-vs-field); Two-Key for consequential COORD decisions 
with logged Reasons & Weighings. 
 
Implementation (pilot → scale) 
 
• 0-3 months: publish curriculum & rubrics; stand up supervision pools; RPL portal; first 
micro‑hub pilots; conditional licences for legacy roles. 
• 3-6 months: first OSCE sittings; EPA throughput checks; renewal policy finalised; 
dashboard tiles live for capability metrics. 
• 6-12 months: scale to additional regions; publish calibration report; begin mini‑OSCE 
renewals for early cohort; de‑rostering rules active. 
• 12-24 months: legacy titles sunset; full rural parity coverage; scholarships round 2; 
independent evaluation published. 
 
Interfaces with other standards 
 
• Safety & Restrictive Practices: IDC leads timekeeping, initiates 72‑hour learning reviews, 
contributes to fade plans. 
• Truth‑by‑Design: IDC records two‑party e‑receipts; participates in roster‑to‑claim 
cross‑checks. 
• Independent Verification (DSC): IDC collaborates with DSCs; provides field artefacts for 
Reasons & Weighting and Contradiction Matrix. 
• Service Model Standards: IDC plans and rehearses ordinary‑place roles; facilitates 
switching where conflicts exist. 
• Data, Dashboards & Privacy: IDC contributes to minimum datasets and adheres to DPIA 
controls. 
 
Risks & mitigations 
 
• Throughput bottlenecks: micro‑hubs, tele‑OSCEs, shared examiners, scholarship‑backfill 
funding. 
• Paper credentials without practice: enforce observed EPAs and file‑vs‑field candour 
checks at renewal. 
• Rural attrition: staged sunsetting; local educator development; travel supports. 
• Cost pressure on small providers: pooled supervision; shared assessment calendars; 
procurement preferences for compliant providers. 

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• Change fatigue: Plain English/Easy Read packs; predictable renewal windows; 
recognition of excellence on dashboards. 
 
Rural/remote execution rules 
 
• Tele‑OSCE with dual‑camera where useful; recordings used for calibration. 
• Satellite OSCE hubs at least quarterly; travel & standby recognised. 
• Weather‑miss protocol: reschedule within 10 business days; document adjustments to 
supervised‑practice minima. 
• Local Inclusion Multiplier: EPAs should show ties to local civic assets (councils, 
libraries, sport, arts, faith). 
 
Note: This body of the white paper consolidates duplicated clauses and defaults to the most 
stringent thresholds and integrity settings. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

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Safety & Restrictive Practices Standard 
 
Purpose and scope 
 
This standard makes least-restrictive by default operational. It sets a restraint hierarchy, 
timekeeping, 72-hour learning reviews, and fade plans so that any use of restraint is 
minimised, audited and converted into learning. It applies to all supports across home, 
community, education, health and justice interfaces. 
[See Workforce Standard  -  Integrated Disability Clinician (IDC); Independent Verification 
Standard; Service Model Standards (life in community).] 
 
Definitions (used consistently) 
• Restrictive practice / restraint (umbrella). Any practice that limits movement, 
liberty, decision-making or access (e.g., chemical, physical, mechanical, 
environmental, seclusion). 
• Timekeeping. Logging start/stop time and total minutes under restraint. 
• 72-hour learning review. A mandated review within 72 hours of any restraint use to 
test alternatives, decide next steps and update the fade plan. 
• Fade plan. A documented plan to reduce and remove restraint, with clear steps, 
supports and checkpoints. 
• Sentinel event. Any restraint event resulting in injury, emergency service 
involvement, or seclusion >15 minutes. 
[See Definitions and Principles.] 
Principles and legal baseline 
• Person-first and rights-based: supported decision-making; accessible information; 
respect for culture and language. 
• Proportionality and necessity: restraint only as a last resort to prevent imminent 
harm when less-restrictive alternatives are demonstrably ineffective or unavailable. 
• Shortest time possible: time-bound, continuously observed, with active efforts to de-
escalate and cease. 
• Documented alternatives: what was attempted before restraint; why it failed; what 
will be tried next. 
• Duty to fade: every incident must move practice toward less restriction. 
• Candour: accurate file-vs-field alignment; no euphemisms (e.g., “comfort hold”). 
[See Governance, Assurance and Risk; Independent Verification Standard.] 
Restraint hierarchy (summary) 
[Full detail lives in Appendix: Restraint Hierarchy & Timekeeping Standard.] 
1. Prohibited practices (never permitted): prone restraint; pain-compliance 
techniques; seclusion without observation; mechanical restraint not prescribed by a 
clinician for therapeutic use; any practice that restricts breathing or circulation; 
withholding essential care/food/fluids; aversive stimuli. 
2. Red-light (exception-only, high authorisation): seclusion in a safe room; chemical 
restraint outside a clinical prescribing plan; mechanical devices used for restraint 

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rather than therapy. Requires pre-authorisation (or post-incident authorisation within 
24 hours for emergencies) and automatic DSC flag. 
3. Amber (time-limited with line-manager authorisation): brief physical holds for 
imminent harm; environmental restrictions in clearly defined circumstances (e.g., 
locked kitchen where ingestion risk is active). Requires timekeeping and 72-hour 
learning review. 
4. Green (least-restrictive alternatives): de-escalation; sensory regulation; graded 
exposure; change of setting; communication/AAC supports; coaching; call-in of 
additional support. Must be attempted and documented before any red/amber use 
unless risk is immediate. 
Emergency override: Where there is immediate risk of serious harm and no time for 
alternatives, use the least-restrictive effective option; commence timekeeping immediately; 
notify supervisor; complete incident pack and 72-hour learning review. 
Authorisation and notifications 
• Before use (planned): where foreseeable, obtain authorisation consistent with the 
hierarchy; write alternatives, monitoring plan, and fade plan. 
• After use (unplanned/emergency): notify supervisor within 2 hours; log time; 
inform the authorised representative/guardian as appropriate; initiate review. 
• Sentinel event: notify safeguarding bodies as required; automatic DSC referral. 
• Tribunal/public advocate interfaces: where orders or conditions exist, align with 
those instruments and record compliance. 
[See Independent Verification Standard.] 
Timekeeping standard 
• Record start time, end time, total minutes, type of restraint, location, reason, 
alternatives attempted, persons present, injury check, debrief offered. 
• Real-time or within 2 hours of cessation (not end-of-week). 
• Minutes roll to dashboards as restrictive minutes per 1,000 support hours (de-
identified publicly; person-level in family view with role-based access). 
[See Data, Dashboards and Privacy.] 
The 72-hour learning review (mandatory) 
 
Trigger: any restraint use, including chemical restraint outside a prescribing plan, seclusion, 
or mechanical restraint; any physical hold >1 minute; any sentinel event. 
Participants: the person (with supports of choice), IDC lead, supervisor, relevant clinician if 
involved, authorised representative/guardian as appropriate. 
Agenda (minimum): 
1. Reconstruct events (file vs field; body-cam footage is not required and is out of scope 
unless lawfully in use for safety; if present, follow privacy rules). 
2. Check human rights tests; confirm least-restrictive applied; assess proportionality and 
necessity. 
3. Surface triggers/functions; review alternatives attempted and their timing. 
4. Decide concrete next alternatives; update fade plan (tasks, responsible person, 
timeline). 

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5. Confirm medication reconciliation (if chemical restraint used or ED/hospital contact 
occurred). 
6. Document what will be measured before the next case review (e.g., minutes, 
indicators, participation targets). 
Output: signed review note; updated fade plan; data pushed to dashboards; DSC 
referral where thresholds met. 
Fade plan (required elements) 
• Goal: named least-restrictive alternative(s) to replace the restraint; target conditions 
where restraint drops to zero. 
• Steps: graded tasks, environmental adjustments, skill-building sessions, 
communication/AAC supports. 
• Supports: who is involved (family, peers, clinicians), resources required, scheduling 
in ordinary places. 
• Monitoring: indicators to track (e.g., incidents/week, minutes, participation); review 
cadence (weekly/fortnightly). 
• Sunset: explicit date to reassess and retire the plan if restraint is no longer used. 
[See Service Model Standards (life in community).] 
Hospital/ED handover and medication reconciliation 
• Handover: reason for presentation; what was attempted; restraint type/time; injuries; 
communication needs; consent/guardian details. 
• Reconciliation (within 72 hours): current meds; changes made; adverse effects; 
monitoring plan; responsible prescriber; next review date. 
• Back-transfer: confirm supports, prescriptions, and monitoring tasks before 
discharge; log in documentation and dashboards. 
[See Workforce Standard  -  IDC; Data, Dashboards and Privacy.] 
 
Primary Care & Health Stewardship 
GP Interface & Hand-back Protocol 
Objective. Translate clinical visits into safer daily life and clear records. 
 
Before the visit: accessible reason-for-visit sheet; communication passport; meds list; 
interpreter/Auslan/AAC booked. 
 
During: supported conversation; dignity-of-risk notes if procedures are proposed. 
 
After (within 48h): GP hand-back to IDC/family - diagnoses; changes; monitoring; next 
steps; red-flags; who to call. 
 
Metrics: hand-back completeness; follow-up kept; adverse events; interpreter timeliness. 
[See Data, Dashboards and Privacy; Service Model Standards (life in community).] 
ED Interface & Safe Discharge 

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Objective. Avoid revolving-door ED attendances and post-discharge confusion. 
 
At triage: flag cognitive disability; use communication passport; call IDC/representative 
where appropriate. 
 
During care: document alternatives tried; if restraint occurs, timekeep and trigger a 72-hour 
learning review. 
 
Discharge (within 24h): provide an accessible discharge summary; ensure scripts supplied; 
transport arranged; first GP/IDC appointments booked. 
 
Metrics: unplanned re-presentations ≤7/30 days; discharge summary availability in family 
view; reconciliation completed within 72h. 
[See Safety & Restrictive Practices Standard.] 
Pharmacy Psychotropic Stewardship 
Objective. Prevent drift into chemical restraint; ensure indication, consent and review. 
Minimum requirements: 
• Indication & consent: clear diagnosis/target symptoms; supported decision-making; 
guardian consent if applicable. 
• Dose/duration guardrails: start-low/go-slow; explicit review dates; stop dates for 
PRN where appropriate. 
• Monitoring: vitals/metabolic where relevant; side-effects logged; behaviour/function 
outcomes tracked. 
• De-prescribing pathway: taper plan with triggers; pharmacist/GP review; IDC 
observes effect in ordinary places. 
• DSC triggers: off-label high dose; multi-psychotropic stacks; absent monitoring; 
capacity/consent disputes. 
Metrics: % scripts with active review date; monitoring completion; de-prescribing 
success; ED visits related to adverse effects. 
Appendix mapping: Appendix AB  -  Pharmacy Psychotropic Stewardship 
Protocol (add to Appendices index). 
[See Safety & Restrictive Practices Standard; Independent Verification Standard.] 
Dental Desensitisation & Oral Health Access 
Objective. Replace crisis dentistry with planned, low-arousal care. 
Protocol (graded): 
• Week 1-2: meet team; sit in chair; AAC rehearsal; no instruments. 
• Week 3-4: mirror only; short contact; reward schedule; Easy Read visuals. 
• Week 5-6: scaler/polish with pauses; noise-control; sensory aids. 
• If sedation considered: rights tests; consent; proportionality; recovery plan; post-
visit review. 
Prevention: fluoride varnish schedule; brush/visual routine at home; diet advice in Plain 
English. 
 

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Metrics: completed preventive visits; sedation rate; successful graded sessions; caries 
incidents. 
 
Appendix mapping: Appendix AC  -  Dental Desensitisation Protocol  
[Additional: See Equity, First Nations Partnership and Access; Service Model Standards (life 
in community).] 
 
Primary Care & Health Stewardship (explicit) 
 
Roles and responsibilities 
• IDC: prepare passports; attend (or tele-attend) where appropriate; translate GP/ED 
instructions to the weekly community schedule; capture two-party e-receipts for 
sessions linked to health tasks. 
• IDC lead: initiates timekeeping, convenes 72-hour review, drafts/updates fade plan, 
ensures handover/reconciliation if applicable. 
• Clinicians (GP/ED/Pharmacy/Dental): apply supported decision-making; set review 
dates; hand-back within timelines; avoid coercive shortcuts. 
• Clinician (where prescribing/clinical oversight exists): confirms indications; 
monitors effects; contributes to fade planning. 
• Supervisor/Provider: confirms authorisation; checks documentation quality; ensures 
review completion; escalates sentinel events; allocates resources for fade plan. 
• Providers: schedule and transport; ensure interpreter/AAC; store artefacts; act on red-
flags. 
• Families/representatives: consent where appropriate; review summaries in family 
view; raise concerns early. 
• Family/guardian/advocate: participates in reviews; co-designs fade plan; receives 
plain-language summaries. 
[See Independent Verification Standard; Governance, Assurance and Risk.] 
• DSC (triggered cases): performs file-vs-field calibration; reviews Reasons & 
Weighting and Contradiction Matrix inputs; supports publishable reasons. 
• DSC (when triggered): test file-vs-field claims; verify consent/capacity handling; 
recommend remedies. 
[See Independent Verification Standard; Service Model Standards (life in 
community).] 
Artefacts and data (where templates live) 
• GP/ED hand-back & discharge forms: Appendix D  -  Handover & Medication 
Reconciliation Pack (expand to include GP sheet + ED discharge summary). 
• Pharmacy stewardship one-pager: Appendix AB. 
• Dental protocol: Appendix AC. 
• Event model: add gp.handback.created, ed.discharge.created, pharm.review.due to 
the API/webhook list. 
[See Data, Dashboards and Privacy; Appendices (indexed).] 
Restraint incident log (timekeeping) with alternatives tried. 
• 72-hour learning review note and attendance. 

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• Fade plan (current version and history). 
• Handover/reconciliation sheet (if relevant). 
• Injury and debrief notes (offered/accepted; follow-up actions). 
• DSC referral and outcomes (if triggered). 
Note: Appendices provide templates; the section of record is here. 
[See Appendices (indexed): Restraint Hierarchy & Timekeeping Standard; Handover 
& Reconciliation Pack.] 
Metrics and indicators (dashboards) 
• Primary: restrictive minutes/1,000 support hours; 72-hour review compliance rate; 
fade-plan success (restraint-free weeks/months); medication reconciliation completion 
(within 72 hours). 
• Quality signals: proportion of incidents with alternatives documented; DSC 
calibration variance (file vs field); sentinel events (rate and close-out time). 
• Equity: interpreter use at reviews; rural response times; First Nations partner 
involvement where relevant. 
Public tiles are de-identified with suppression rules; family view shows a person’s 
own data with role-based access. 
[See Data, Dashboards and Privacy; Evaluation & Continuous Learning.] 
Training and competence (IDC alignment) 
• Mandatory modules: least-restrictive practice; de-escalation; communication/AAC; 
timekeeping; 72-hour review procedure; fade-plan design; handover/reconciliation; 
cultural safety. 
• Observed competence: at least two observed de-escalations and one post-incident 
72-hour review led by the candidate. 
• Renewal: refreshers every 3 years (or earlier after sentinel events); mini-OSCE 
station on least-restrictive practice. 
[See Workforce Standard  -  IDC.] 
Equity, cultural safety and access 
• First Nations partnership: option to involve community representatives; respect for 
cultural protocol; consider on-Country supports. 
• CALD/Auslan access: interpreter at reviews; translated summaries; AAC artefacts 
where required. 
• Rural parity: tele-reviews permitted with two visual streams where possible; micro-
hub support for on-site coaching; travel supports for in-person de-briefs when needed. 
[See Equity, First Nations Partnership and Access.] 
Technology and environment safeguards 
• Technology is not care: screens and monitoring devices cannot substitute for 
presence or be used as covert restraint. 
• Environmental restraint: any locks/alarms used to limit access must be justified, 
logged, time-bound and included in fade plans. 

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• Recording devices: if used lawfully for safety, follow DPIA; restrict access; never 
publish person-identifying footage; log retention in the audit register. 
[See Data, Dashboards and Privacy.] 
Risk management, escalation and sanctions 
• Escalation: sentinel event → immediate senior review; DSC referral; safeguarding 
notification as required. 
• Provider risk register: track patterns (e.g., repeated restraint in a location/shift); 
assign corrective actions with deadlines. 
• Sanctions ladder (linked): advice → corrective plan → probation → suspension → 
contract exit/referral; publication rules apply. 
[See Governance, Assurance and Risk; Truth-by-Design Standard.] 
Interfaces with other standards 
• Workforce (IDC): competence, observations and renewal include least-restrictive 
stations and reviews. 
• Truth-by-Design: incident data integrity; dashboard publication; immutable audit 
logs. 
• Independent Verification: DSC calibration for contested/high-risk cases; feed into 
Reasons & Weighting and Contradiction Matrix. 
• Service Model Standards: fade plans embed ordinary-place practice; community 
roles used as alternatives. 
• Data, Dashboards and Privacy: DPIA, schema conformance, suppression rules. 
• Evaluation & Continuous Learning: peer-review of incidents; publish quality 
summaries; refresh the hierarchy if evidence changes. 
Implementation (switch-on order) 
• 0-3 months: publish hierarchy; train IDC/supervisors; enable timekeeping fields; 
stand up 72-hour review template; begin dashboard tile for restrictive minutes. 
• 3-6 months: enforce review compliance; launch fade-plan template; start DSC 
referrals per thresholds; publish first de-identified tiles. 
• 6-12 months: calibrate across regions; publish learning themes; integrate 
handover/reconciliation data; red-team stress test (restraint spike scenario). 
• 12-24 months: demonstrate reduction in restrictive minutes/1,000 hours; increase 
fade-plan success; independent evaluation released. 
[See Implementation Roadmap (Switch-On Order).] 
 
 
 
 

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Truth-by-Design Standard 
 
Purpose and scope 
 
This standard shifts integrity from after-the-fact auditing to built-in controls that run as work 
is done. It covers two-party e-receipts, roster-to-claim cross-checks, proportionate sanctions, 
publication rules, and privacy-by-design. It applies to all funded supports across home, 
community, education, health and justice interfaces. 
[See Data, Dashboards and Privacy; Governance, Assurance and Risk; Service Model 
Standards (life in community).] 
Principles (what “truth by design” means here) 
• In-flow verification: capture the evidence as the task completes, not weeks later. 
• Two-party attestation: both sides (person/authorised representative and provider) 
confirm what occurred. 
• Proportionate effort: controls add minimal load and replace duplicative paperwork. 
• Privacy-first: role-based access, suppression rules and immutable audit logs. 
• Explainable signals: publish quality signals that families can act on and providers 
can improve against. 
Two-party e-receipt (minimum standard) 
 
Definition. A digital receipt confirmed by the person (or authorised representative) and the 
provider for supports delivered. It supports accessible modes (AAC, Easy Read, translated 
text) and offline capture with secure sync. 
Required fields (minimum): 
• Who/role: pseudonymous person ID (family-view shows name by role), provider ID, 
worker identifier (hashed for public tiles), attestor role 
(self/parent/guardian/advocate). 
• What: support type/category; brief purpose linked to plan goal; duration 
(start/end/total minutes); location (coarse category such as home, workplace, 
community). 
• How confirmed: attestation method (tap/signature/AAC cue/witness), timestamp, 
device/application ID. 
• Notes & outcomes: short free text (Plain English/Easy Read), goal progress marker 
(yes/partial/no), optional attachment (e.g., photo of completed task with consent). 
• Exceptions/declines: standard codes including E7 (declined) with reason text. 
Process requirements: 
• Window: issue within 48 hours of service; family-view available on creation; 
reminder at 72 hours if not attested. 
• Accessibility: AAC options (symbols, yes/no selectors, audio prompts); translated 
strings; large-type Easy Read. 
• Corrections: both parties can propose corrections; system retains an immutable 
version history. 
Outputs: 
• Family view: complete receipt history with role-based access. 
• Public tiles: coverage rate and timeliness (de-identified). 
[See Appendices (indexed): Minimum Two-Party E-Receipt JSON Schema.] 

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Roster-to-claim cross-checks (before payment) 
 
Purpose. Detect mismatches and outliers early; route only exceptions to human review. 
Inputs. Rostered shifts, time-and-attendance, e-receipt events, claim lines, approved location 
categories. 
Checks (minimum set): 
• Existence: claim has a matching roster and e-receipt within time tolerance. 
• Timing: start/finish within tolerance; overlapping shifts flagged. 
• Quantity: hours claimed match roster ± agreed tolerance (e.g., 6%). 
• Location: coarse category consistent with plan and roster. 
• Role: worker role matches authorised scope (e.g., IDC vs non-IDC). 
Exception categories (illustrative): E1 No matching roster; E2 No e-receipt; E3 
Overlap; E4 Excess variance; E5 Role/scope mismatch; E6 Location mismatch; E7 
Declined by person/representative; E8 Other (free-text). 
Handling: 
• Auto-approve clean lines; queue exceptions with triage timers; suspend payment 
only for material risk categories (e.g., E1/E2/E5) while review occurs. 
• SLA: 5-10 business days to resolve exceptions; ageing items escalate to provider exec 
and commissioner. 
• Learning loop: recurring patterns trigger provider improvement plans or DSC 
referral. 
[See Independent Verification Standard; Governance, Assurance and Risk.] 
Sanctions ladder (proportionate, publishable) 
 
Purpose. Apply consistent consequences tied to verified findings; deter gaming without 
chilling innovation. 
Rungs: 
1. Advice/education: low harm; fix within 30 days. 
2. Corrective action plan: medium risk; named actions with deadlines; re-audit. 
3. Probation/heightened oversight: high risk; monthly verification; restricted intake. 
4. Suspension of claims/services: serious non-compliance; safety/integrity at risk. 
5. Contract exit/referral: persistent or egregious breaches; notify safeguarding/health 
regulators as applicable. 
Publication rules: rungs 3-5 produce public quality signals (de-identified aggregate 
for small providers; named where thresholds are met and lawful). 
Right of reply: provider statement shown alongside sanction summary; expiry date 
on public listing when rectified. 
[See Governance, Assurance and Risk.] 
Financial Safety & Fiduciary Checks 
Purpose 
Prevent financial abuse or mishandling of funds linked to disability supports; make money 
flows traceable, two-party attested and auditable without burdening families. 
Minimum controls 

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• Two-signature rule for significant discretionary spends (person/authorised 
representative + provider). 
• E-receipt tagging for purchases on behalf of the person (purpose, link to plan goal, 
receipt image where consented). 
• Gift/benefit register (provider-level); conflict-of-interest declarations for staff. 
• Cash handling discouraged; if unavoidable, float logs + same-day reconciliation. 
• Guardianship orders respected; fiduciary role recorded in family view. 
Exceptions & escalation 
• Flags: repeated cash use; missing receipts; personal goods repeatedly billed as 
program costs. 
• Action: verify via cross-checks; require corrections/refunds; escalate to DSC if 
pattern persists; apply sanctions ladder as needed. 
Publication & dashboards (signals people can use) 
• Public tiles (quarterly): e-receipt coverage; timeliness; exception rate and age; 
proportion resolved; sanctions ladder distribution; DSC referral/turnaround stats 
related to integrity issues. 
• Family view: full receipt history, exception status, resolutions; clear “what next” 
actions. 
• Suppression rules: small-cell suppression (e.g., n<5); k-anonymity thresholds set and 
documented; no person-identifiable information in public tiles. 
[See Data, Dashboards and Privacy; Evaluation & Continuous Learning.] 
Privacy, security and DPIA requirements 
• DPIA mandatory for e-receipt and cross-check pipelines; updated on material 
change. 
• Data minimisation: collect only what’s needed for attestation and cross-check; 
coarse location categories (no continuous GPS unless explicitly lawful and 
consented). 
• No biometrics/emotion inference for attestation. 
• Role-based access: family vs provider vs commissioner views; least-privilege 
defaults. 
• Immutable audit log: append-only event store; time-stamped corrections; external 
audit readable. 
• Retention & deletion: person-level retention rules documented; routine purge of 
transient caches. 
[See Data, Dashboards and Privacy.] 
Technology and accessibility guardrails 
• Offline-first capture: receipts cache and sync when back online; integrity checks re-
run on sync. 
• Standards & APIs: open schema; versioned endpoints; vendor-neutral; conformance 
tests published. 
• Accessibility: WCAG-aligned UI patterns; AAC libraries; Easy Read flows; 
interpreter prompts for CALD/Auslan contexts. 

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• No “screens-as-care”: technology evidences care - it does not replace presence in 
ordinary places. 
[See Service Model Standards (life in community).] 
Roles and responsibilities 
• Frontline (IDC): capture receipt, offer accessible attestation modes, explain purpose 
in Plain English/Easy Read, resolve simple exceptions. 
• Supervisors/Providers: maintain conformance, resolve exceptions within SLA, run 
monthly variance reviews, submit improvement plans for patterns. 
• Commissioner/Program owner: operate cross-check service, manage sanctions 
ladder, publish tiles and release notes, oversee DPIAs and audits. 
• Families/Authorised representatives: review/attest receipts; request corrections; 
view exception status and outcomes. 
• DSC (triggered cases): calibrate file-vs-field facts where integrity concerns or 
sanctions rungs ≥3 arise. 
[See Independent Verification Standard; Governance, Assurance and Risk.] 
Metrics and indicators (for dashboards) 
• Spend e-receipt coverage; exception rate/ageing for financial flags; conflict register 
completeness; refund cycle time. 
[See Data, Dashboards and Privacy; Governance, Assurance and Risk.] 
• Coverage & timeliness: % of supports with two-party e-receipts; % attested within 
48/72 hours. 
• Match & variance: roster/claim match rate; average absolute variance; overlap rate. 
• Exceptions: exception rate by category (E1-E8); median time-to-resolution; ageing 
over SLA. 
• Sanctions: distribution across rungs; time on rung; remediation success rate. 
• Equity: AAC/translator usage in attestations; rural micro-hub conformance; 
accessibility error rate. 
• Privacy & safety: DPIA status; audit log completeness; privacy incidents (target: 
zero). 
[See Data, Dashboards and Privacy; Evaluation & Continuous Learning.] 
Implementation (switch-on order) 
• 0-3 months: publish schema and conformance tests; pilot e-receipt in two sites (one 
metro, one rural); enable minimal cross-checks (existence & timing); set exception 
SLAs; draft sanctions policy. 
• 3-6 months: add variance and role checks; turn on exception queues; begin 
publication of de-identified tiles; first DPIA complete; training for providers and 
families. 
• 6-12 months: expand to full exception set; calibrate thresholds; begin sanctions 
publication per rules; run first external audit of logs and conformance. 
• 12-24 months: scale statewide; integrate with DSC triggers; red-team a data/privacy 
incident scenario; publish independent evaluation and method notes. 
[See Implementation Roadmap (Switch-On Order).] 

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Interfaces with other standards 
• Workforce (IDC): documentation and e-receipt capture are core competencies; 
observed and renewed at OSCE/mini-OSCE. 
• Safety & Restrictive Practices: incident/review artefacts flow into dashboards; no 
covert monitoring used as restraint. 
• Independent Verification: DSC uses receipts/logs to test file-vs-field and support 
Reasons & Weighting and Contradiction Matrix. 
• Data, Dashboards and Privacy: schema, suppression, DPIA, publication cadence. 
• Governance, Assurance and Risk: sanctions ladder ownership; escalation; stress-
testing (e.g., fraud ring, mass exception spike). 
Risks and mitigations 
• Admin load creep: design to replace existing paperwork; one-touch capture; autofill 
from roster; shared APIs. 
• False positives: tune thresholds; sample reviews; publish method notes; allow 
provider right-of-reply. 
• Gaming (tick-and-flick): random DSC spot-checks; compare narrative richness over 
time; correlate with outcomes (presence/participation). 
• Digital exclusion: offline-first; paper-assist with scan-to-attest; interpreter/AAC 
availability; micro-hub support in rural areas. 
• Privacy breaches: stringent DPIA, role-based access, immutable logs, rapid 
revoke/rotate keys, regular red-team tests. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

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Independent Verification Standard - Decision Support 
Consultant (DSC) 
 
Neutral verification for file‑vs‑field calibration, lawful decisions, and publishable reasons. 
 
This consolidates: “Independent Verification Standard  -  Decision Support Consultant 
(DSC)” and “A_DSC_IDC_Reform_Blueprint”. Where thresholds or safeguards differed, the 
most rigorous (‘higher-of’) setting has been adopted and repetition removed. 
 
Purpose & scope 
 
Establish a neutral DSC function to reconcile documentation with lived reality, apply rights 
tests, and enable timely, plain‑English Reasons & Weighting. Applies to contested or 
high‑risk matters across home, community, education, health and justice interfaces. 
 
What independent verification is (and is not) 
 
• Is: a structured, time‑bound enquiry that compares file assertions with field observations 
and neutral artefacts; applies least‑restrictive, proportionality and necessity tests; 
produces a Reasons & Weighting (R&W), a Contradiction Matrix, and an 
Independent‑Reasoning Certificate (IRC). 
• Is not: case management, clinical prescribing, eligibility setting, or an adversarial 
‘gotcha’. The DSC tests evidence quality and reasoning and supports lawful, reviewable 
decisions. 
 
Triggers (when a DSC must be engaged) 
 
• Safety high‑risk: sentinel restraint events; any Red‑light restraint; repeated Amber use 
without fade‑plan progress. 
• Integrity high‑risk: sanctions ladder ≥ rung 3; systemic exceptions (E1/E2/E5) from 
roster‑to‑claim cross‑checks; suspected document fabrication or identity misuse. 
• Decision high‑risk: contested capacity/consent; restrictive living arrangements; orders 
significantly limiting rights; high‑stakes transitions (hospital discharge; custody release). 
• Pattern risk: repeated complaints on the same issue; outlier metrics on dashboards; 
unresolved contradictions across professionals or records. 
• Discretionary: commissioner/tribunal/public advocate direction; Ombudsman referral. 
• Two‑Key escalation: engage DSC where co‑sign is disputed, delayed beyond p95 
threshold, or a liberty‑reducing decision is proposed. 
• Bias/capture signal: repeated same‑pair co‑signs beyond rotation rules trigger DSC 
sampling. 
 
Independence & ethics 
 
• Structural separation: DSCs report to an independent unit (commissioner/tribunal office), 
never to providers whose cases they examine. 
• Cooling‑off & conflicts: declared interests; DSC rotation; no DSC may verify a provider 
for whom they’ve worked in the last 24 months. 

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• Code of conduct: person‑first; least‑restrictive by default; cultural safety; candour; 
privacy‑by‑design; procedural fairness. 
• Right to be heard: the person and their authorised representative/guardian are offered a 
chance to contribute and review a plain‑language summary before publication 
(time‑limited to avoid delay). 
 
Role boundaries & interfaces 
 
• Tribunal/Commissioner: decision‑maker of record; receives DSC artefacts and issues 
determinations. 
• IDC: field practitioner; collaborates in evidence assembly and learning reviews; cannot 
over‑rule DSC but may append technical responses for the record. 
• DSC: neutral verifier; does not author service plans or set eligibility; provides R&W, 
Contradiction Matrix, and IRC; issues a Calibration Memo for Two‑Key cases. 
 
Two‑Key interface (decision support) 
 
• Calibration Memo (Two‑Key): short file‑vs‑field check of co‑sign independence, R&W 
quality, and will‑and‑preferences fidelity. 
• Where Two‑Key pairs repeat above rotation limits, the DSC samples ≥20% of 
determinations in the next quarter. 
• Liberty‑reducing proposals (e.g., restrictive living, involuntary medication) require DSC 
engagement prior to final co‑sign unless an Emergency Quorum is invoked, in which case 
a 72‑hour post‑hoc review is mandatory. 
 
Workflow (intake → enquiry → decision support → publication) 
 
1. Intake & triage (24-48h): confirm trigger; assign DSC; notify parties; collect 
consent/information‑sharing basis. 
2. Evidence pack (days 1-5): assemble file (plans, notes, incidents, medication, 
rosters/claims, e‑receipts), policies/orders, previous decisions. 
3. Field observation (days 3-10): observe typical contexts; speak with the person using 
preferred communication (AAC etc.); confirm environmental factors; avoid disruption. 
4. Reconciliation (days 7-12): compare file assertions to field observations and neutral 
artefacts (receipts, logs); identify contradictions/gaps. 
5. Apply tests (days 10-14): rights tests; safety/clinical handover checks (if relevant); 
integrity checks. 
6. Draft artefacts (days 12-15): complete R&W and Contradiction Matrix; prepare the IRC 
summarising method and findings. 
7. Case conference (days 15-18): DSC, decision‑maker (tribunal/OPA/commissioner), 
IDC/supervisor and relevant clinicians review the draft; confirm remedies and time‑bound 
actions. 
8. Issue & publish (by day 21): decision‑maker issues determination/notice; publish 
plain‑English reasons per privacy rules; log actions and due dates on dashboards. 
 
Artefacts (minimum content & templates) 
 
Reasons & Weighting (R&W) 
 

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• Issues & questions being decided. 
• Evidence table: source, date, relevance, probative weight (scaled descriptors). 
• Applied tests: least‑restrictive/proportionality/necessity; statutory criteria where 
applicable. 
• Findings & reasons in plain English: what evidence was preferred/discounted and why. 
• Remedies & actions: who does what by when (e.g., fade‑plan steps; 
handover/reconciliation; supervision; sanctions rung). 
 
Contradiction Matrix 
 
• Item (fact/claim), File says, Field shows, Other sources (e‑receipts, rosters, clinician 
notes), Resolution (accept/discard/seek more info), Residual uncertainty. 
 
Independent‑Reasoning Certificate (IRC) 
 
• Scope, data sources, observation dates/contexts, communication supports used, conflicts 
declared. 
• Summary of variance (file vs field), key rights tests applied, DSC signature and 
supervisor sign‑off. 
 
Calibration Memo (Two‑Key) 
 
Short, standardised memo that rates co‑sign independence, R&W quality, and 
will‑and‑preferences fidelity; includes a rotation check and any bias/capture notes. 
 
Methods & integrity controls 
 
• Sampling & randomisation: variant banks for interviews and checks; random station 
selection for follow‑up. 
• Identity & provenance: identity checks on key witnesses; metadata checks on digital 
artefacts; chain‑of‑custody for critical records. 
• Calibration & reliability: double‑rated video cases each quarter; inter‑rater reliability 
target κ ≥ 0.7; annual moderation report published. 
• Thin‑market rule: offline‑first receipts and delayed sync permitted; safety gates are never 
waived due to remoteness. 
• Accessibility: reasonable adjustments for the person and for witnesses (interpreters, AAC, 
extra time). Competence/standards remain unchanged. 
 
Publication, privacy & dashboards 
 
• Publication: plain‑English reasons with suppression where n < 5; family‑view dashboards 
show status and due dates without sensitive content. 
• Privacy‑by‑design: DPIA for each template; minimum‑necessary data; role‑based 
visibility; redaction rules for public releases. 
• Tiles: DSC throughput; trigger mix; time‑to‑decision; actions closed on time; R&W 
quality score; contradiction‑resolution rate; Two‑Key rotation health. 
 
Metrics & indicators 
 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 90 
 
• Capability: % DSC‑eligible cases engaged; time‑to‑triage; time‑to‑publication. 
• Safety: restrictive‑minutes/1,000 hours pre/post; 72‑hour review compliance; incident 
recurrence. 
• Integrity: documentation candour match (file‑vs‑field); exception clearance; related‑party 
rate; rotation drift. 
• Equity: interpreter/AAC utilisation; First Nations engagement; rural micro‑hub coverage; 
tele‑verification completion. 
 
Governance, registers & sanctions 
 
• Owner: independent commissioner/tribunal office; DSC unit head accountable for 
separation and calibration. 
• Register: DSC assignments, conflicts, artefact completion, reliability stats, publication 
dates. 
• Sanctions ladder (proportionate): improvement plan → undertakings → administrative 
fines → procurement debarment → publication on registry. 
• Emergency quorum (Two‑Key): 2‑of‑5 with TTL 72h; mandatory post‑hoc DSC review; 
auto‑reversal if review fails. 
 
Rural & remote enablement 
 
• Tele‑verification with dual‑camera where useful; recordings retained for calibration under 
strict access controls. 
• Satellite verification hubs at least quarterly; travel & standby recognised. 
• Weather‑miss protocol: reschedule within 10 business days; document any adjusted 
minima with justification. 
 
Implementation (pilot → scale) 
 
• 0-3 months: publish artefact templates and rubrics; stand up DSC pool; rotation 
scheduler; first micro‑hub pilots. 
• 3-6 months: first publication cycle; reliability report baseline; dashboard tiles live. 
• 6-12 months: expand regions; publish calibration report; embed rotation drift alerts; begin 
annual moderation review. 
• 12-24 months: full rural parity; independent evaluation; integrate with procurement 
preferences for compliant providers. 
 
Interfaces with other standards & roles 
 
• Truth‑by‑Design: roster‑to‑claim and e‑receipt reconciliation; exception ladders 
(E1/E2/E5). 
• Safety & Restrictive Practices: timekeeping; 72‑hour learning reviews; fade‑plan actions. 
• IDC Workforce Standard: documentation exemplars; candour checks; Two‑Key 
handshake; calibration memos. 
• Governance, Assurance & Risk: sanctions alignment; publication; appeals/merits review 
hooks. 
• Data, Dashboards & Privacy: DPIA, suppression rules, tiles schema. 

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Appeals & fairness 
 
• Plain‑English notice of findings and actions with a 10‑business‑day window for factual 
correction (no re‑litigation). 
• Independent merits review where provided in law; DSC provides source pack and 
calibration logs on request. 
 
Decision Support Consultant Essentials 
 
Note: This aligns with the latest IDC and Two‑Key reforms. It consolidates duplicated 
clauses and defaults to the most stringent thresholds and integrity settings. 
DSC Education & Pathways (entry, bridging, renewal) 
 
Purpose: ensure a scalable, independent DSC workforce with consistent judgement, methods 
integrity, and rural parity. The settings below follow the ‘higher-of’ rule aligned to IDC and  
Two‑Key reform. 
 
Entry routes (minimum gates) 
 
• Stream A  -  Law/Policy: degree in law, criminology, public policy, investigation, or 
equivalent; modules in administrative law, evidence, statutory interpretation. 
• Stream B  -  Clinical/Practice: senior IDC/Allied Health/Nursing with supervision 
experience; modules in verification methods and conflicts/independence. 
• Stream C  -  Audit/Integrity: certified auditor/compliance professional; modules in 
disability rights, SDM, least‑restrictive tests, and communication access 
(AAC/interpreters). 
• All streams: pass DSC core curriculum, OSCE/observed stations for interviews, 
contradiction analysis, R&W drafting, and Two‑Key calibration; supervised verifications 
completed under rotation. 
 
Curriculum map (minimum content & hours  -  higher‑of applied) 
 
• Structured learning: 180-240 hours (administrative law; evidence & probity; 
least‑restrictive/necessity/proportionality tests; investigation methods; cognitive disability 
& communication access; bias/heuristics; statistics & sampling; DPIA & 
privacy‑by‑design; Two‑Key calibration). 
• Applied micro‑modules: 60-100 hours (justice/hospital/housing interfaces; rural 
protocols; interpreter scheduling; e‑receipts and roster‑to‑claim analytics; dashboard 
literacy). 
• Equity modules: ≥20 hours (First Nations partnership; CALD/Auslan; trauma‑informed 
enquiry; cultural pairing for second key where feasible). 
• Simulation & drills: ≥20 hours (contradiction interviews; rights testing under time 
pressure; publication/redaction exercises). 
 
Supervised practise & observation 
 
• Supervised verifications: 200-300 hours across ≥6 cases (mix of safety, integrity, and 
decision‑risk triggers). 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 92 
 
• Observed elements: ≥8 observed interviews (≥3 external supervisor), ≥3 case 
conferences, ≥3 publication/redaction exercises. 
• Documentation integrity checks: ≥4 file‑vs‑field reconciliations producing Contradiction 
Matrices and R&Ws. 
• Calibration: participation in quarterly double‑rating; κ target ≥0.7 with actions logged if 
below. 
 
DSC OSCE/Observed stations (must‑pass) 
 
• Interview & communication access with AAC/interpreters (plain‑language summary 
back‑check). 
• Contradiction Matrix build from mixed‑quality records under time constraint. 
• R&W drafting with proportionality/necessity analysis and clear discounting of weak 
evidence. 
• Two‑Key Calibration Memo with independence/rotation check and bias/capture notes. 
• Privacy & DPIA station: redaction and publication pathway with suppression rules (n<5). 
 
Equivalency & Bridging (legacy roles → DSC) 
 
• Equivalency: mapped knowledge checks (admin law; rights tests; DPIA; Two‑Key; 
conflicts), OSCE/observed stations, and portfolio (R&Ws, Contradiction Matrices, IRCs, 
Calibration Memos). 
• Bridging: AO‑2 plan with gap modules named; supervised hours 150-240 depending on 
stream; booked OSCEs; provisional verification scope (shadow/assist only) until pass. 
• Outcomes rubric: PASS / BRIDGE / DEFER / FAIL; safety/integrity gates 
non‑negotiable. 
 
Renewal & CPD 
 
• Cycle: every 3 years; mini‑OSCE (2-3 observed stations) or workplace assessment; 
candour check (file‑vs‑field sample). 
• CPD: ≥60 hours/year (≥12 hours equity); at least one rural/micro‑hub engagement per 
cycle where practicable. 
• Recency: ≥600-900 hours verification activity (mix of lead/shadow) per 3‑year cycle. 
 
Wage bands, incentives & rural parity 
 
• DSC (Verifier): AUD $120k-$145k base (signal only; jurisdictional bargaining applies). 
• Senior DSC (Lead): AUD $145k-$170k; Principal DSC (Calibration/Methods): AUD 
$170k-$200k. 
• Rural/remote loadings: 10-20% plus travel/standby recognition; bonded scholarships for 
shortage regions and priority domains (paediatrics; justice transitions). 
• Outcome‑linked incentives (QPIP‑Integrity): pool of 2-3% tied to publication timeliness, 
contradiction resolution rate, rotation health, and reduction in re‑work/appeals 
(risk‑adjusted; anti‑gaming). 
 
Caseload & rotation (capture/bias guardrails) 
 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 93 
 
• Caseload: complexity‑weighted caps; automatic alert at 85% threshold; forced rotation at 
100%. 
• Rotation: no single DSC‑provider pairing >X% of cases/quarter (policy to set X, typical 
25-33%); automatic sampling if exceeded. 
• Separation: no verification of a provider within 24 months of employment/consultancy; 
cooling‑off on conflicted matters; emergency quorum only with 72‑hour post‑hoc review. 
 
Procurement & registry hooks 
 
• Procurement: contracts require independent DSC engagement for Two‑Key domains and 
publish rotation health; preference for vendors with ≥90% on‑time actions from DSC 
findings. 
• Registry: DSC licence, currency, κ statistic by quarter, conflict declarations, rotation 
metrics, publication timestamps. 
 
 
Tribunal/OPG/OPA Practice  -  Candour by Template (worked guidance) 
Purpose (why a template) 
Enable clear, publishable reasons that reconcile file-vs-field facts and respect rights, culture 
and privacy. The template reduces variance, speeds publication and supports appeal-proof 
decisions. 
[See Artefacts; Publication and privacy; Governance, Assurance and Risk.] 
Plain-English Reasons (structure) 
Use this micro-template when drafting Reasons & Weighting (R&W): 
1. Issue(s) to decide  -  one sentence each in Plain English/Easy Read. 
2. What we looked at  -  list sources (observations, e-receipts, timekeeping, plans, 
clinical notes, interviews, law/policy). 
3. What matched / what didn’t  -  short contrasts anchored to the Contradiction 
Matrix. 
4. Rights tests applied  -  least-restrictive, proportionality, necessity (and any statutory 
criteria). 
5. What we decided and why  -  the finding(s) with the highest-weight evidence 
named. 
6. What happens next  -  time-bound actions, owners, due dates; how parties can seek 
review/appeal. 
7. How we protected privacy/culture  -  redactions, interpreter use, cultural brokers 
engaged. 
Keep the public reasons to ~600-1,200 words; attach the full R&W and Matrix in the 
family/decision-maker view. 
[See Data, Dashboards and Privacy.] 
Weighting scale (probative value, with descriptors) 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 94 
 
• Very high  -  first-hand observation by DSC; consistent with neutral artefacts (e-
receipts, timekeeping); contemporaneous; method sound. 
• High  -  first-hand or expert source; minor gaps; still aligns with neutral artefacts. 
• Moderate  -  second-hand; partial corroboration; method limits noted. 
• Low  -  hearsay; inconsistent with neutral artefacts; material bias/conflict not 
mitigated. 
• Nil  -  unverifiable; contradicted by multiple stronger sources; method unsound. 
Modifiers: contemporaneity, corroboration breadth, cultural/linguistic fit 
(interpreter/AAC), conflict of interest, expertise scope. 
[See Reasons & Weighting; Contradiction Matrix.] 
Contradiction Matrix  -  how to use it 
Populate rows for each contested fact: Item → File says → Field shows → Other sources → 
Resolution → Residual uncertainty. 
Rules of thumb: 
• Prefer neutral artefacts (receipts/logs) over recollection. 
• Record why lower-weight evidence was discounted (bias, method, mismatch). 
• If uncertainty remains, state it and design actions to reduce it (e.g., targeted 
observation, medication review). 
[See Independent-Reasoning Certificate.] 
Procedural fairness (right to be heard) 
• Notice: state the questions and what materials will be considered. 
• Disclosure: provide the draft Matrix summary in Plain English/Easy Read (and 
translated/Auslan where relevant). 
• Response window: reasonable but time-limited to meet the 21-day publication SLA. 
• Consideration: show how responses changed weightings/findings. 
• Record: log interpreter/AAC use and any cultural broker involvement. 
[See Equity, First Nations Partnership and Access.] 
Redaction & suppression playbook (publication safety) 
• Remove person-identifiable health details not necessary to understand reasons; 
pseudonymise; generalise location. 
• Apply small-cell suppression and k-anonymity in any annexed summaries; never 
publish raw artefacts. 
• For cultural content - publish the principle and action, not sensitive specifics; store 
detail only in the family view. 
[See Data, Dashboards and Privacy; Appendix S.] 
Worked example types (see Appendix AG) 
• Capacity & consent (interpretation + psychotropic change). 
• Seclusion beyond limits (restraint spike with missing timekeeping). 
• Environmental restriction vs safety (locked areas and fade plan). 
• Integrity exception E1/E2 (no roster/receipt) tied to sanctions rung. 
• Disputed participation claims (presence minutes vs receipts/tracker). 

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• Interpreter unavailable (procedural fairness and adjournment logic). 
Each exemplar shows the filled Matrix, R&W with weights, and the published 
summary (Plain English + Easy Read), with redaction notes. 
Quality gates (ready to publish) 
• Completeness: Matrix filled; R&W covers issues, tests, findings, actions. 
• Clarity: public summary ≤1,200 words; reading grade appropriate; headings match 
this template. 
• Equity: interpreter/AAC recorded; cultural broker engaged where relevant. 
• Privacy: DPIA reference, redactions listed; small-cell and k-anonymity checks pass. 
• Timeliness: publication within 21 days of intake unless legally extended (reason 
noted). 
[See Metrics and indicators; Publication and privacy.] 
Decision outputs → actions (closing the loop) 
• Convert remedies into time-bound actions (fade-plan steps, medication review, 
switching, supervision). 
• Push actions to provider/coordinator dashboards with owners/dates; show progress in 
family view; summarise completion in public tiles. 
• If sanctions are engaged, link to the rung and expiry/recurrence rules. 
[See Truth-by-Design Standard; Governance, Assurance and Risk.] 
Publication and privacy 
• What is published: a plain-English summary of reasons, remedies/actions and dates; 
anonymised data for public tiles (e.g., publication timeliness, variance rates); 
provider-level sanctions signals where rules allow. 
• What is not published: person-identifiable health information, exact addresses, 
sensitive cultural details, or any data breaching suppression thresholds. 
• Family/guardian view: full R&W (with redactions only where law requires) and 
action tracking. 
• Method notes: release notes describe method changes and calibration results to 
maintain trust. 
[See Data, Dashboards and Privacy; Governance, Assurance and Risk.] 
Roles and responsibilities 
• DSC: conduct enquiry; complete artefacts; recommend remedies; attest IRC. 
• Decision-maker (tribunal/OPA/commissioner): issue determination; adopt R&W; 
ensure actions/timeframes are lawful and proportionate. 
• Provider: supply documents; enable observation; implement remedies; report 
completion. 
• IDC/supervisor: attend review; implement practice changes (e.g., fade-plan steps; 
documentation fixes). 
• Clinicians (if involved): clarify prescribing rationale/monitoring; adjust plans as 
needed. 
• Families/authorised representatives: contribute lived information; receive plain-
language summary; track actions. 

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• Program owner: maintain DSC SOP, templates, calibration and publication cadence. 
Metrics and indicators (dashboards) 
• Turnaround: median days intake→publication; % published within 21 days. 
• Calibration variance: % of cases where file assertions diverge from field 
observations on key points; variance trend over time. 
• Quality of reasons: peer-review score (structure, clarity, test application); re-work 
rate; appeal/overturn rate. 
• Action completion: % remedies delivered on time; repeat-issue rate within 90/180 
days. 
• Equity & access: interpreter/AAC use; First Nations partnership engagement; rural 
on-site vs tele-observation mix. 
• Privacy: publication errors (target: zero); DPIA status; audit-log completeness. 
[See Evaluation & Continuous Learning; Data, Dashboards and Privacy.] 
Calibration and quality assurance 
• Double-rating: ≥10% of cases second-reviewed by a different DSC; inter-rater 
reliability published. 
• Case sampling: targeted re-checks on high-impact decisions and sanctions rungs ≥3. 
• Examiner development: quarterly moderation using de-identified cases; library of 
annotated R&W exemplars. 
• Feedback loop: providers and families can submit factual corrections; versioned 
publications record amendments. 
• Red-team tests: simulate adversarial scenarios (e.g., perfect paperwork with weak 
field practice; data gaps; conflicting clinician opinions). 
Interfaces with other standards 
• Safety & Restrictive Practices: sentinel events and Red-light restraint trigger DSC; 
outputs drive fade-plan revisions and training focus. 
• Truth-by-Design: DSC uses e-receipts, roster/claim data and exception logs as 
neutral artefacts; integrity findings feed the sanctions ladder. 
• Workforce (IDC): DSC observations contribute to file-vs-field candour checks used 
at renewal; aggregate themes inform curriculum updates. 
• Service Model Standards: DSC verifies presence/participation claims and switching 
friction reports in real contexts. 
• Data, Dashboards and Privacy: publication rules, suppression thresholds and audit 
logs apply to all DSC outputs. 
• Governance, Assurance and Risk: ownership, escalation and proportionate 
sanctions; whistleblower protections. 
• Evaluation & Continuous Learning: peer-review, improvement cycles, and 
standard refresh cadence. 
Implementation (switch-on order) 
• 0-3 months: stand-up DSC unit; publish SOP; release R&W and Contradiction 
Matrix templates; train DSCs and decision-makers; start with safety high-risk 
triggers; DPIA completed. 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 97 
 
• 3-6 months: add integrity and pattern-risk triggers; commence double-rating; publish 
first de-identified DSC tiles (turnaround; variance). 
• 6-12 months: expand coverage; publish method notes and calibration report; integrate 
with sanctions ladder publication; red-team a contested decision scenario. 
• 12-24 months: statewide availability; independent evaluation of DSC impact on 
appeals, safety outcomes and market quality signals. 
Risks and mitigations 
• Role creep (becoming case managers): SOP and KPIs tied to verification outputs, 
not service delivery. 
• Perceived bias: structural separation; rotation; declared interests; double-rating; 
right-of-reply in publications. 
• Delay risk: 21-day service level; escalation when clinical/safety decisions cannot 
wait; interim safeguards documented. 
• Chilling candour: publish method notes that reward truthful documentation; 
sanctions focus on verified misconduct, not error disclosed and corrected. 
• Privacy exposure: strict redaction rules; suppression thresholds; immutable audit 
logs; rapid correction protocol. 
 
Example; Template Baseline Formats 
 
A1. Disclosure and Candour Certification (for parties/agencies) 
Case reference: ____ Party/Agency: ____ Date: ____ 
Contact for follow-up (name/role/email/phone): ______________________ 
Certification (tick to confirm): 
1 ☐ I have taken reasonable steps to locate and disclose all material documents and data in 
my possession or control that are relevant to this matter (including emails, rosters, care notes, 
incident logs, medication charts, discharge letters, behaviour/PBS data, mealtime/IDDSI 
plans, seizure protocols, e-receipts, CCTV/audio per policy, and prior orders). 
2 ☐ Any known contradictions, gaps or missing records are identified below. 
3 ☐ I understand this certification may be checked against organisational records and 
exceptions (roster-to-claim sweeps, audit trails). 
4 ☐ Where the participant has requested appeal materials, I confirm we will supply our 
materials within 10 business days and cooperate so that transcripts/recordings can be made 
available inside the statutory window (see Appendix C, C1.4). 
List of materials disclosed (title/date/author/location): 
• _____________________________________________________________ 

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Known contradictions or gaps (describe and state mitigation): 
• _____________________________________________________________ 
Signature: __________________ Name/Role: ________________ Date: ____ 
Privacy note: Attach only what is necessary. De-identify where lawful; mark health 
information clearly; do not include third-party names without consent or lawful basis. 
 
 
A2. Minimum Investigation Standard (MIS) Checklist (for investigations) 
Case reference: ____ Investigator: ____ Tier: ☐ Triage ☐ Standard ☐ Complex 
Target SLAs: Triage ≤5 bd; Standard ≤20 bd; Complex ≤40 bd (record reasons for any 
variance). 
Contacts completed (dates/outcomes): 
• Person (incl. communication method/AAC): __________________________ 
• Representative/guardian: ________________________________________ 
• Family/primary carer: ___________________________________________ 
• Service provider(s) (frontline + manager): _________________________ 
• Health/allied health (GP, pharmacy, SLP/OT/psych): ________________ 
• Others (e.g., school/police/ambulance): ____________________________ 
Required documents on file (tick/attach source): 
☐ Incident summaries ☐ Medication charts/MAR ☐ Discharge letters 
☐ Chronology ☐ Behaviour/PBS data ☐ Communication profile/AAC 
☐ Mealtime/dysphagia (IDDSI) plan ☐ Duty statements/rosters 
☐ Prior orders/authorisations & compliance notes ☐ E-receipts & claims extracts 
☐ Seizure plan/rescue-med governance ☐ Documentation integrity sample/audit 
Credibility rubric applied: ☐ Yes (attach notes) 
Contradictions logged in Matrix: ☐ Yes 
Equity lens applied (First Nations/CALD/Auslan/women/LGBTQ+/55+/rural): ☐ Yes 

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SLA met: ☐ Yes ☐ No (reasons) ____________________________________ 
Supervisor review completed: ☐ Yes Date: ____ 
Closure memo maps findings → evidence and options grid: ☐ Yes 
Supervisor sign-off: __________________ Date: ____ 
Rule of evidence: No single source is determinative where contradictions exist. Use the 
Contradiction Matrix and resolve on the record (see A3). 
 
A3. Contradiction Matrix (registry tool) 
Assertion 
(material 
fact) 
S
o
u
r
c
e 
A 
S
o
u
r
c
e 
B 
S
o
u
r
c
e 
C 
Weight 
(H/M/L) 
Status 
(C=Corroborated / 
CT=Contradicted 
/ U=Unverified) 
Action 
(Oral/Collateral/
Defer) 
Owner 
& Due 
Notes/MIS 
deviation 
 
• Populate for every material assertion. 
• Flag items for oral testing at hearing; record who resolves and by when. 
• Link to evidence locations (doc ID/time-stamp). 
 
 
A4. Independent-Reasoning Certificate (IRC) 
I, [name], certify that: 
1 I independently evaluated and weighted each material item of evidence using the Reasons 
& Weighting table. 
2 I used the Contradiction Matrix to reconcile conflicts; any unresolved conflicts are 
explained in Reasons. 
3 I applied rights and least-restrictive tests and considered supported decision-making 
with communication access. 
4 I identified any MIS deviations and explained why. 
5 Where an appeal is requested, the appeal-ready bundle (reasons, matrix, schedules, 
audio/transcript request) has been initiated so materials are available within the 
statutory time. 
Signed: __________ Role: Member/Delegate Date: ____ 
 

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A5. Reasons and Weighting  -  Fillable Shell 
Case reference: ____ Decision-maker(s): ____ Date: ____ 
Issues: ________________________________________________________ 
Options considered (with least-restrictive analysis): ________________ 
Evidence summary (complete for each material source): 
• Source: __________ Accepted/Rejected/Partial; Weight (H/M/L); Why: 
__________________ 
Applied tests: rights; least-restrictive; SDM/capacity; risks & safeguards; why this option 
best fits the person’s will and preferences. 
Decision and conditions: ________________________________________ 
Review trigger(s) (incl. restraint fade/expiry): ______________________ 
Equity considerations (First Nations/CALD/Auslan/55+/rural): _________ 
Plain-language summary (for the person/family): ____________________ 
Publication note: Prepare a de-identified digest entry (per Appendix H) and mark any 
suppression requirements. 
 
A6. Gold-Standard Case Note and Rubric 
Structure 
1 What happened (objective, time-stamped). 
2 What mattered to the person (will, preferences, consent). 
3 Risks and actions taken (link to plans: IDDSI/seizure/PBS). 
4 Next steps (who/what/when; review date). 
5 Attachments & consent status (include e-receipt/roster link). 
Scoring (0-2 each; pass ≥7/10): objectivity; completeness; risk linkage; timeliness; 
readability. 
Redaction/Privacy: remove non-party identifiers; mark sensitive content. 
 
 
 
 

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A7. Seizure Response Drill Script 
Scenario: [type, duration, environment] 
Checks (pass/fail): 
☐ Start time recorded; timer running. 
☐ Protect head/airway; clear hazards; recovery position when safe. 
☐ Follow person’s plan; thresholds observed (e.g., ≥5 min or cluster as per plan → 
escalate). 
☐ Rescue-med steps practised (only if authorised); post-ictal monitoring explained. 
☐ Documentation complete; family/ally notified; review booked (≤7 days). 
Assessor comments / Retraining required: __________________________ 
 
A8. Mealtime & IDDSI Audit Sheet 
Person: ____ IDDSI level(s): Solids [ ] 3 [ ] 4 [ ] 5 [ ] 6 [ ] 7 Liquids [ ] 0 [ ] 1 [ ] 2 [ ] 3 [ ] 4 
Set-up: positioning; supervision level; equipment ready; IDDSI flow/fork-drip test 
performed and recorded. 
During meal: pacing; prompts; safe swallow strategies; signs of distress recognised; 
escalation pathway. 
Post-meal: upright time; oral care; hydration; documentation; issues for review. 
Result: Pass/Fail items; Action plan with owner & due date. 
Safety rule: Never change textures without a documented plan. Sentinel aspiration events 
must trigger a 72-hour review (see Appendix P-3; Appendix E). 
 
A9. OSCE Checklists (module pack) 
Modules 
• Mealtime/dysphagia (IDDSI) • Seizure response (incl. rescue-med delegation where 
permitted) 
• Medication safety & delegation • AAC in conversation 
• PBS de-escalation & data capture • Documentation integrity 
For each module include: station set-up; candidate tasks; critical errors (automatic fail); 
scoring rubric (0-2 items; pass thresholds); identity check; debrief script; moderation notes. 
Reliability: annual moderation and inter-rater reliability target κ ≥0.7. 

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A10. Two-Party e-Receipt  -  Data Fields and Format 
Minimum fields (aligns with Appendix H & schema): 
• receipt_id (UUID); case_ref (if applicable) 
• Participant: participant_id (pseudonymous), participant_name (if consented), consent 
preference (text/checkbox), attestation modality (signature/initials/AAC yes-no/ 
PIN/QR) 
• Worker: worker_id, worker_name, provider_id 
• Service: service_code, service_description, date, start_time, end_time, duration_minutes, 
location_type (home/community/tele/custody/ED) 
• Integrity hooks: roster_ref, claim_ref, incident_flag (Y/N), notes_redacted (Y/N) 
• Attestations: participant_attest_ts, worker_attest_ts, attestation_status 
(complete/pending/declined) 
• Change log: created_at, updated_at, created_by, edited_by, change_hash 
• Offline metadata: device_id, offline_flag (Y/N), first_seen_server_ts, sync_status, 
optional coarse geo_area (only with consent) 
• Accessibility: interpreter_used (Y/N/type), AAC_used (Y/N/type) 
Formats: PDF and CSV; JSON via API (published by administrator). 
Timing: capture within 48 hours of delivery; offline capture allowed with sync ≤ 7 days in 
rural/remote contexts. 
Retention & access: per statutory schedule; role-based access; full audit trail. 
Corrections: allow post-issue correction with dual attestation and preserved change log (no 
hard deletes). 
 
A11. Accessibility & Translation Addendum (applies to all A-templates) 
• Offer Easy-Read, large print, and interpreter/Auslan. 
• Provide a Yes/No card and picture board for on-site completion. 
• Confirm preferred language and communication method; record on each form. 
• Allow phone/in-person completion with a staff scribe where requested (scribe signs). 
 

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A12. Data Protection Hooks (cross-reference Appendix I) 
• Each template includes a Privacy Notice: purpose, lawful basis, who sees the data, 
retention, and contact for corrections. 
• Any new fields or linkages require a DPIA update; record version/date on the form footer. 
• Mark sensitive health or cultural information and apply need-to-know access. 
 
A13. Publication Mapping (Appendix H) 
• A1/A2/A5 feed Tribunal_Decision_Summary (reasons_weighting_applied_pct, MIS 
deviation). 
• A10 feeds Integrity_Exceptions (coverage and anomaly resolution). 
• A7/A8 and OSCE modules inform Provider_Quarterly_Dashboard (safety and 
competence tiles). 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

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Shared Decision Standard  -  Two-Key Guardianship       
(No One Decides Alone) 
 
Aligned with IDC Workforce Standard and Independent Verification (DSC). 
 
This consolidates the Two‑Key standard with prior Two‑Key elements from the DSC/IDC 
Reform Blueprint, Policy & Legislative Pack, Audit Information Pack, and Implementation 
Order. It adopts the most rigorous (‘higher‑of’) integrity settings and removes duplication.  
 
Purpose & scope 
 
Establish a failsafe for consequential decisions so no one decides alone, aligning tribunals, 
guardians/OPG/OPA, providers, COORD/OPS licence classes, and families around a single, 
auditable pattern. 
 
Decision classes (in scope) 
 
• Life/Home: entry/exit or switch of residence; restrictive living arrangements; SDA/SIL 
moves. 
• Liberty & Health: consent to high‑risk procedures/sedation; psychotropic 
initiation/continuation; restraint authorisations beyond emergencies. 
• Finance & Relationships: long‑term finance/estate moves; material program switches 
affecting income, supports, or close relationships. 
• Other high‑stakes matters named by the tribunal/commissioner. 
 
Core rule 
 
• Two independent keys (co‑sign) OR Multi‑Person Guardianship (MPG) quorum for all 
in‑scope decisions. 
• Every decision carries a short Reasons & Weighting (R&W) note (issues, evidence, 
probative weight, applied tests) and a Will‑and‑Preferences record in the person’s words 
(with SDM/BIWP support where capacity fluctuates). 
• DSC calibration engaged where facts are contested or risk is high; DSC reports 
file‑vs‑field with method transparency. 
 
Independence & conflict rules 
 
• Co‑signers must be independent: no direct financial conflicts; not both employed by the 
same provider team making/benefiting from the decision. 
• Rotation of principal signers; declarable relationships recorded. Same‑pair limits per 
quarter; breaches trigger DSC sampling ≥20% next quarter. 
• If a second guardian/independent key is unavailable or recused, pair via the Independent 
Pairing Pool (IPP) within 72 hours (tele‑co‑sign acceptable with ID check and recorded 
reason). 
• COORD independence: coordination separated from provision; where a COORD 
influences a consequential decision, R&W + Two‑Key details must be logged. 

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Emergency pathway (Tier‑0) 
 
• Make safe using the least‑restrictive option likely to succeed. 
• Log within 24 hours; hold a 72‑hour learning review; update the fade plan if 
restraint/sedation occurred. 
• The follow‑up decision must meet Two‑Key/MPG rules (no exceptions). 
 
Quorum models 
 
• Standard: Two‑Key (two independent keys) for most decisions. 
• MPG: a small quorum (e.g., 3) for complex/contested liberty‑reducing decisions, 
including an external member. 
• Emergency Quorum: 2‑of‑5 with TTL 72h for time‑critical safety events; mandatory 
post‑hoc DSC review within 72h; auto‑reversal if review fails. 
 
Roles & interfaces 
 
• Tribunal/Commissioner: decision‑maker of record; issues determinations; sets practice 
notes. 
• Guardians/OPG/OPA: provide a key or quorum seat; maintain rotation and conflict 
registers. 
• IDC (workforce): leads SDM, timekeeping, and the 72‑hour learning review; prepares 
clean documentation packs. 
• COORD licence class: logs R&W where they influence decisions; maintains 
independence from provision. 
• DSC (independent verification): provides Calibration Memo; reconciles file‑vs‑field; 
supports lawful, reviewable decisions. 
 
Artefacts (minimum, one‑page forms wherever possible) 
 
• Two‑Key Decision Record  -  R&W short form + Will‑and‑Preferences. 
• Conflict & Independence Check  -  pairing record + rotation limits + declarations. 
• Tier‑0 Log & 72‑Hour Review  -  emergency documentation and learning actions. 
• DSC Calibration Memo  -  independence, R&W quality, will‑and‑preferences fidelity 
(where engaged). 
• Publication Note  -  privacy‑safe, de‑identified summary for dashboards, where 
applicable. 
 
Publication & dashboards 
 
• Measures: two_key_coverage_pct; co‑sign_median_hours and p95_hours; 
tier0_exception_rate_per_100_decisions; review_72h_coverage_pct; rotation health; 
equity lenses (First Nations, CALD, rural/remote, gender, age bands). 
• Suppression: n < 5; family‑view dashboards show status/due dates without sensitive 
content. 
• Tiles feed quarterly public releases; provider‑level publication limited to quality signals 
(no personal data). 

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Rural & thin‑market parity 
 
• IPP with 72‑hour SLA to source independent keys; tele‑co‑sign with identity check; 
micro‑hub pairing rosters. 
• Scholarships/loadings handled elsewhere; here: execution parity with no dilution of 
standards. 
 
Anti‑collusion & capture guards 
 
• Rotation rules: enforce same‑pair limits; publish rotation health metrics. 
• Bias/capture signals: trigger DSC sampling and, where needed, a full verification. 
• Related‑party checks: automatic prompts during pairing; require written reasons if 
proceeding with mitigations. 
 
Implementation (switch‑on order) 
 
9. 0-3 months: Tribunal Practice Note; OPA/OPG Investigations Code addendum; IPP stood 
up; templates live; internal dashboards. 
10. 3-6 months: pilot (1 metro + 1 rural); ≥90% coverage; median co‑sign ≤72h moving to 
≤48h; begin external dashboards (de‑identified). 
11. 6-12 months: scale to priority cohorts; publish first calibration & rotation report; embed 
emergency‑quorum post‑hoc checks. 
12. 12-24 months: regional parity; independent evaluation; incorporation into procurement 
and accreditation conditions. 
 
Compliance & sanctions 
 
• Non‑compliance ladder: improvement plan → licence/contract conditions → 
administrative fines → de‑preference/de‑barment → publication on registry. 
• Provider claims contingent on recorded co‑sign/quorum for in‑scope decisions; 
exceptions logged, trended, and reviewed. 
 
Note: This is a wage‑free information metric by design and aligns with IDC and DSC 
standards. It defaults to the most stringent thresholds and integrity controls, emphasising 
simple artefacts and rotation health to prevent capture. 
 
 
 
 
 
 
 
 
 

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Service Model Standards (life in community) 
 
Purpose and scope 
 
This standard replaces “screens-as-care” and “restraint as default” with real presence and 
participation in ordinary places. It makes supports visible in the community, strengthens roles 
and relationships, and ensures switching is easy when services don’t fit. It applies across 
home, community, education, health and justice interfaces. 
 
[See Workforce Standard  -  Integrated Disability Clinician (IDC); Truth-by-Design 
Standard; Safety & Restrictive Practices Standard.] 
 
Principles 
 
• Person-first, least-restrictive by default. Supports are built around the person’s 
goals and preferences. 
• Ordinary places first. Shops, parks, libraries, clubs, education, training, workplaces - 
where other people are. 
• Dignity of risk. Practise skills in real contexts with proportionate safeguards. 
• Coordination independent from provision. Reduced conflicts; decisions made in 
the person’s interest. 
• Easy switching. Low friction to change providers, coordinators, or modalities. 
• Equity. First Nations partnership, CALD/Auslan access, rural enablement baked in. 
• Privacy-by-design. Role-based access, clear consent, minimal data, open schemas. 
[See Equity, First Nations Partnership and Access; Data, Dashboards and Privacy.] 
 
Minimum requirements (what every plan and week must show) 
 
• Accessible plan (Plain English and Easy Read) with 3-5 clear goals, each mapped to 
roles in ordinary places. 
• Weekly community schedule that names the place, role/task, people involved and 
how success will be practised and measured. 
• Skill-building method (graded steps, prompts, generalisation plan, who coaches, 
where and how often). 
• Transport plan (how to get there safely and reliably; contingencies). 
• Communication supports (AAC, interpreters, visual cues). 
• Safeguards (reasonable adjustments, early-warning cues, de-escalation steps, fade 
plans if restraint ever used). 
• Family/ally involvement (who does what; micro-modules for the home routines that 
sustain progress). 
• Switching protocol (how to exit a poor fit; time limits; who helps). 
• Visibility via two-party e-receipts and presence/participation trackers that feed family 
and public dashboards. 
[See Truth-by-Design Standard; Safety & Restrictive Practices Standard.] 
 
Accessible plans (content and format) 
 

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• Front page: person’s priorities in their words; communication preferences; cultural 
considerations. 
• Goal cards (per goal): ordinary place(s); target role(s); practice steps; who supports; 
dignity-of-risk notes; success indicators. 
• Supports grid: IDC tasks vs. family/ally tasks; frequency/dose; review dates. 
• Easy Read insert: icons, photos (with consent), short lines; available in language 
preference; Auslan video link where applicable. 
• Version control: date, owner, next review; change log in plain English. 
[See Data, Dashboards and Privacy.] 
 
Community Access Kits (making ordinary places ready) 
 
“Quiet Hours” Community MOU (shops, libraries, pools) 
 
Purpose. Partner with local venues to create predictable, low-arousal access without special 
segregation. 
 
Minimum clauses (Appendix AD): 
 
• Weekly quiet hour slot(s) with adjusted lighting/sound; staff brief; priority queue 
where practical. 
• Visible signage; Plain English/Easy Read posters; optional symbol cards. 
• Contact person; feedback loop; review every 6 months. 
How used: IDCs schedule graded tasks during quiet hours; e-receipts tag 
community.quiet_hour. 
Metrics: attendance; role steps achieved; customer feedback; incidents (target low, 
learning documented). 
[See Service Model Standards (life in community); Equity, First Nations Partnership 
and Access.] 
 
Transport Staff Pocket Card (bus, rail, community transport) 
 
Purpose. Help drivers/guards support people with cognitive disability calmly and lawfully. 
 
Front (Appendix AE): 6 prompts: greet; allow time; use simple choices; confirm destination; 
offer seat change; call for help (not police) unless safety risk. 
Back: do/don’t list (no forced handling; avoid loud commands; offer alternatives); QR to a 
60-second explainer video; local micro-hub contact. 
 
Use: carried by IDC/person; shown to staff if needed; transport operators brief crews 
quarterly. 
 
Metrics: reported issues; on-time arrivals; successful graded trips; complaints resolved. 
[See Equity, First Nations Partnership and Access.] 
 
Where to get help / Artefacts & Templates 
 
• Appendix AD  -  “Quiet Hours” Community MOU Template (venue checklist, 
posters, comms script). 

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• Appendix AE  -  Transport Staff Pocket Card (print-ready PDF + text for in-app 
wallet). 
• API events: community.quiet_hour.created, transport.support.requested. 
[See Data, Dashboards and Privacy.] 
 
Roles and responsibilities 
 
• Where a service recommendation would trigger an in-scope decision, providers attach 
the Two-Key Decision Record and confirm co-sign status before acting, unless Tier-0 
applied. 
• IDC: plan graded visits; brief venue/transport staff; capture receipts; debrief in Plain 
English/Easy Read. 
• Venues/Transport operators: adopt MOU/pocket card; brief staff; provide a single 
contact; log incidents/feedback. 
• Coordinator: line up partners; ensure quiet hours align with the weekly schedule; 
solve access blockers. 
• Equity Lead/Micro-hubs: supply training; maintain poster stocks; collect feedback 
themes for quality summaries. 
 
Community presence and participation (how we practise) 
 
• Presence = minutes/hours in ordinary places; Participation = roles, relationships, 
contribution. Both are required. 
• Graded exposure: start with short, predictable tasks; extend time, complexity and 
independence. 
• Natural supports: staff coach toward peers, neighbours, colleagues - not permanent 
one-to-one shadowing. 
• Role-building: volunteer → trainee → paid role pathways where suitable; link to 
education/training. 
• Health interface: GP/dentist/physio appointments are real-world practice 
opportunities (navigation, waiting, communicating needs). 
[See Workforce Standard  -  IDC; Evaluation & Continuous Learning.] 
 
Coordination independent from provision 
 
• Structural independence: the person’s coordinator cannot be employed by (or 
bonus-linked to) their primary service provider. 
• Conflict declarations: any related-party link is declared, mitigated or replaced. 
• Choice architecture: present 2-3 viable options with Plain English/Easy Read 
comparisons; record the person’s reasons. 
• Review cadence: check fit at 30/90 days; earlier if red flags arise (missed shifts, low 
presence, repeated incidents). 
[See Governance, Assurance and Risk.] 
 
Switching protocol (low-friction change) 
 
• Triggers: poor fit, repeated cancellations, safety concerns, loss of trust, conflict of 
interest, move of home/school/job. 

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• Exit & Entry Data Set (minimum): goals and progress, weekly schedule, 
communication supports, risk/safeguards, meds handover (if relevant), upcoming 
commitments. 
• Time limits: 
o Provider issues Exit Data Set within 10 business days of notice. 
o New provider confirms start within 5 business days of receiving it. 
• Continuity: no gap >10 business days unless the person chooses a pause; interim 
supports arranged where needed. 
• Costs: publish any break fees up-front; ban “soft lock-in” via opaque rostering rules. 
• Support to switch: coordinator arranges comparisons, trials, and first-week routines 
at the new provider. 
[See Truth-by-Design Standard; Independent Verification Standard.] 
 
Provider Transition Pack (switching & onboarding) 
Purpose and outcomes 
Make switching simple, fast and safe so people move to a better fit without gaps. Outcomes: 
(1) continuity in ordinary places; (2) no re-telling of history; (3) risks controlled; (4) first-
week wins visible in family view. 
[See Switching protocol; Data, Dashboards and Privacy.] 
What the current provider must deliver (Exit) 
• Within 10 business days: complete the Exit & Entry Data Set (Appendix M) 
including: goals & current progress; weekly community schedule; communication 
passport/AAC; cultural plan; risk/safeguards; meds/handover status; upcoming 
commitments; contact points. 
• Quality check: Plain English/Easy Read summary; translated where relevant. 
• Warm handover: one joint call (or meeting) with new provider and coordinator; 
confirm dates and first-week plan. 
• Continuity: maintain supports until the agreed start date unless the person chooses a 
pause. 
What the new provider must deliver (Entry) 
• Within 5 business days of receiving the Exit set: confirm start date; assign IDC lead; 
book interpreters/Auslan; schedule week-1 ordinary-place sessions. 
• First week (minimum): 2-3 community sessions; at least one role-building step; 
confirm transport plan; capture two-party e-receipts. 
• Family view: show first-week plan and receipts; provide a contact for 
troubleshooting. 
Coordinator (independent) duties 
• Present 2-3 viable options (Plain English/Easy Read comparisons). 
• Manage time limits; escalate delays at day 6/11; record reason codes for friction. 
• Confirm funding/admin changes; update dashboards. 

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Risk, safety and health continuity 
• Move any fade plan and open 72-hour learning review tasks with the Exit set; book 
the next review date. 
• Ensure GP/ED hand-backs and prescriptions move with the person; book GP within 
7 days if there was a recent incident. 
[See Safety & Restrictive Practices Standard; Primary Care & Health Stewardship.] 
Where to get help / Artefacts & Templates 
• Appendix M  -  Switching Protocol & Exit/Entry Data Set (expanded to include 
Transition Pack checklists and week-1 plan). 
• Family-facing “Welcome & What to Expect (Week 1)” one-pager (Plain English/Easy 
Read)  -  included in Appendix M. 
Metrics (dashboards) 
• Time to issue Exit set; time to confirm start; days of gap (target ≤10 business days, 
person-chosen pauses excluded). 
• Week-1 completion rate; presence minutes in first 14 days; exception rate on receipts; 
family confidence index change. 
[See Data, Dashboards and Privacy.] 
Frequently Asked Questions (Plain English) 
Q. Do we have to explain everything again? 
A. No. The Exit & Entry Data Set moves with you so you don’t retell your story. You can 
add updates in your words. 
Q. How long should switching take? 
A. Exit set in 10 business days, new start confirmed in 5. If not, the coordinator escalates and 
helps you choose alternatives. 
Q. Can we try the new provider first? 
A. Yes. A trial week can be scheduled; two-party e-receipts show what happened so you can 
decide. 
Q. What if the new provider isn’t ready? 
A. You can choose another provider. Delays are recorded and published as switching friction 
metrics. 
Q. Who sees my information? 
A. Only people with a role-based need (you/your representative, old and new provider, 
coordinator). Public tiles are de-identified. 
Q. We live rural - will we wait longer? 
A. The standard applies everywhere. Micro-hubs, tele-onboarding and travel supports are in 
place to keep parity. 

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Q. Can we change our coordinator too? 
A. Yes. Coordination is independent from provision; you can switch coordinators under the 
same time limits. 
Skill acquisition in real contexts 
• Task analysis & prompting: break tasks into steps; fade prompts; track 
independence. 
• Generalisation: practise in at least two settings with two different people. 
• Dose & spacing: specify frequency and length; avoid long gaps that reset progress. 
• Home practice: short micro-modules for families/allies; no specialist jargon; video or 
photo prompts with consent. 
• Feedback loop: IDC provides brief, plain-language updates tied to the goal card - 
visible in family view. 
[See Workforce Standard  -  IDC.] 
Technology and environment 
• Assistive tech supports communication, planning and navigation; it does not replace 
real presence. 
• Remote/tele-supports are supplemental (e.g., brief coaching), not the main event 
unless expressly chosen for a time-limited purpose. 
• Environmental adjustments (lighting, noise control, signage) are enablers - not 
covert restraint. If an adjustment restricts access, treat it under the Safety standard. 
[See Safety & Restrictive Practices Standard; Data, Dashboards and Privacy.] 
Justice Interfaces (police, courts, corrections) 
 
Police Academy Integration Plan  -  Cognitive Disability Capability 
Objective. Ensure first contact with police reduces harm, protects rights and connects people 
to supports, not cycles of escalation. (See Appendix AN  -  Police Academy Integration Plan 
(detailed curriculum & OSCE)) 
Minimum capabilities (academy & in-service): 
• Recognise cognitive disability indicators; use supported conversation and Easy Read 
cautions/warnings; arrange interpreters/Auslan/AAC when needed. 
• Apply least-restrictive by default and de-escalation; avoid “screens-as-care” body-
cam replay loops that retraumatise. 
• Know local referral pathways (IDC/micro-hub, crisis alternatives) and how to initiate 
safe handover. 
• Document using a short Field Contact Note that translates to the person/family view 
where lawful. 
Delivery: scenario-based modules with lived-experience co-trainers; refresher every 
24 months; rural delivery via micro-hubs and tele-simulation. 
Metrics: use of accessible cautions; interpreter/AAC usage; diversion to support vs 
charge; repeat-contact rate. 
[See Safety & Restrictive Practices Standard; Equity, First Nations Partnership and 
Access; Data, Dashboards and Privacy.] 
Corrections & Custody Health Standard 

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Objective. Make custody safe, rights-respecting and connected to health, not a clinical dead-
end. 
Minimum requirements: 
• Screen on entry for cognitive disability; create a communication passport within 72 
hours. 
• Medication reconciliation on entry/transfer/discharge; no psychotropic “standing 
orders” without indication, consent and monitoring. 
• Practice in ordinary routines: education, work, visits - use graded tasks and AAC, 
not isolation. 
• Restrictive practice controls: timekeeping; 72-hour learning reviews; fade plans 
that continue post-release. 
• Health access: GP/dental/mental health pathways with accessible materials; 
interpreter/Auslan access. 
• DSC triggers: sentinel events; seclusion beyond limits; contested capacity/consent; 
recurring complaints. 
Metrics: restrictive minutes/1,000 custody hours; review compliance; healthcare 
access timeliness; DSC turnaround; release continuity readiness. 
[See Safety & Restrictive Practices Standard; Independent Verification Standard; 
Equity, First Nations Partnership and Access.] 
Release Continuity (90-day before/after plan) 
Objective. No one steps from custody into a service void. 
Plan window: start T-90 days before release; continue to T+90 days after. 
Minimum elements: 
• Exit & Entry Data Set prepared and shared; confirm housing; income; ID; phone; 
transport. 
• Health hand-back: GP appointment within 7 days; scripts supplied; pharmacy brief; 
dental follow-up if indicated. 
• Supports live on day 1: IDC community schedule (ordinary places), interpreter 
bookings, assistive tech/AAC ready. 
• Safety learning: active fade plan if restraint occurred in custody; first community 
review within 14 days. 
• Legal/conditions: Easy Read summary of obligations; contact points. 
Metrics: GP seen ≤7 days; IDC session ≤72 hours; presence minutes in first month; 
missed appointments; re-contact with police. 
[See Service Model Standards (life in community); Safety & Restrictive Practices 
Standard; Data, Dashboards and Privacy.] 
Roles and responsibilities 
• Person/authorised representative: choose goals; consent; say what good looks like; 
review progress. 
• IDC: plan and run ordinary-place practice; capture e-receipts; update trackers; coach 
natural supports; escalate safeguards. 
• Coordinator (independent): convene reviews; manage switching; ensure conflicts 
are declared; align other services (education/health). 

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• Provider leadership: resource community sessions (time, transport, staffing); ensure 
accessibility; fix patterns identified by dashboards/DSC. 
• Clinicians (if involved): advise on safe participation; avoid over-medicalising daily 
life; align therapy with roles and routines. 
• Family/allies: practise short tasks between sessions; attend reviews; request help 
early. 
Documentation and artefacts 
• Accessible plan (Plain English + Easy Read). 
• Weekly community schedule. 
• Presence/participation tracker (minutes; role/relationship changes). 
• Two-party e-receipts for delivered supports (with AAC/translation as required). 
• Switching protocol records (Exit & Entry Data Set; dates and outcomes). 
• Review notes and improvement actions. 
Templates live in Appendices (indexed); this section is the authority for content. 
[See Truth-by-Design Standard; Data, Dashboards and Privacy.] 
Metrics and indicators (dashboards) 
• Presence & participation: minutes in ordinary places; number/type of roles; 
relationship breadth. 
• Goal progress: goal attainment per quarter; independence step-ups (prompt fading). 
• Switching: time to issue Exit Data Set; time to onboard; avoidance of gaps; reasons 
for switch. 
• Quality & integrity: e-receipt coverage; documentation candour (file-vs-field); 
missed/cancelled sessions. 
• Equity & access: interpreter/AAC usage; rural micro-hub support; transport 
reliability. 
• Satisfaction & confidence: family confidence index; person-reported experience 
(accessible survey). 
Public tiles are de-identified with suppression rules; person-level is available in 
family view. 
[See Data, Dashboards and Privacy; Evaluation & Continuous Learning.] 
Interfaces with other standards 
• Workforce (IDC): competence in community coaching and documentation is 
observed, examined and renewed. 
• Safety: if restraint occurs in the community, log minutes and run the 72-hour review; 
fade plans embed community alternatives. 
• Truth-by-Design: e-receipts and trackers feed dashboards; exceptions route to 
review. 
• Independent Verification: DSC observes ordinary-place practice in contested/high-
risk cases; checks claims against field reality. 
• Equity: First Nations partnership and interpreters planned rather than ad hoc; rural 
enablement via micro-hubs. 
• Data & Privacy: schema conformance; DPIA for trackers and dashboards. 
Implementation (switch-on order) 

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• 0-3 months: publish accessible plan and weekly schedule templates; start 
presence/participation tracker; train IDC/coordinators on dignity-of-risk coaching; 
activate basic switching protocol and Exit & Entry Data Set. 
• 3-6 months: require e-receipts for community sessions; publish first public tiles for 
presence/participation; embed interpreter booking SOP; run first switching audits. 
• 6-12 months: expand role-building pathways (volunteer/trainee/paid); link health 
appointments as practice opportunities; calibrate trackers across regions; red-team a 
provider-failure scenario (rapid switching). 
• 12-24 months: raise targets for presence/participation minutes; publish improvement 
themes; independent evaluation on participation and quality-of-life proxies. 
[See Implementation Roadmap (Switch-On Order); Evaluation & Continuous 
Learning.] 
Risks and mitigations 
• Token outings without roles: require role/relationship indicators; peer-review 
samples; publish method notes. 
• Shadowing dependence: prompt-fading rules; independence checks at reviews. 
• Transport failure: backup options; micro-hub pooling; travel time funding rules. 
• Cultural/linguistic exclusion: advance interpreter booking; local partnership 
protocols. 
• Digital overreach: remote supports capped unless person chooses; justify and time-
limit any expansion. 
• Switching friction: enforce time limits; escalate aged cases; publish switching 
metrics. 
 
What Can Go Wrong (Even With Love)  -  Risks to Avoid 
(For parents, guardians and volunteers  -  a safe baseline) 
Purpose. To welcome you in, name common traps (even with the best intentions), and show 
practical swaps that protect the person’s rights, safety and growth. This is a baseline  -  it does 
not grant clinical scope. Where the tasks involve clinical risk, an IDC (Integrated Disability 
Clinician) or relevant clinician leads; you support. 
Ten common traps  -  and what to do instead 
1. Taking over because it’s faster → Swap: coach one step, then fade prompts; celebrate 
the person doing the last step. 
2. Rushing conversations → Swap: slow the clock; one idea at a time; check back in 
plain English or Easy Read. 
3. Screens-as-care (defaulting to devices) → Swap: set times/alternatives; prioritise 
real-world roles and routines. 
4. Avoiding ordinary risks → Swap: plan “dignity of risk” with safety nets (who’s 
nearby, how to ask for help). 
5. Talking for the person → Swap: wait time; use AAC/yes-no scaffolds; echo their 
words, don’t replace them. 
6. Paper over practise (nice plans, thin follow-through) → Swap: put the plan on the 
weekly calendar; do the thing in the place. 

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7. Health guesswork (meals, meds, seizures) → Swap: use the mealtime/IDDSI, 
medication and seizure notes the IDC gives you; record concerns; never change meds. 
8. Calling police/ED early → Swap: try low-arousal strategies first; if risk is 
immediate, act to make safe, then inform the IDC. 
9. Privacy slips (photos, stories) → Swap: ask first; share only what’s needed; store 
nothing you don’t need. 
10. Going it alone → Swap: use the weekly schedule, IDC contacts, interpreter/Auslan 
when needed, and family/ally groups. 
Quick checks before I help 
• Right person? I’m the right helper for this task; if not, I call the IDC. 
• Right place? Ordinary place if possible; sensory fit checked; safe transport planned. 
• Right words? Plain English/Easy Read; AAC/interpretation arranged. 
• Right time? Enough time and energy for the person; not rushed. 
• Right record? If we met a goal or tried something new, note it in plain words and tell 
the IDC. 
Low-arousal & safety cues (carry card) 
• Soften voice; reduce audience; offer choices of now/later/elsewhere. 
• One step, then pause. Repeat back what I heard. 
• If distressed: remove extra noise/light/people; offer water; preferred cue 
(object/picture). 
• If risk of harm: move hazards; call for the named backup; then consider emergency. 
Mealtime, meds, seizures  -  red-flag rules 
• Never change food textures, fluids, positioning or meds on your own. 
• Choking risk: stop; forward-lean; follow the plan; call help if unresolved. 
• Seizure: time it; keep airway clear; follow the plan; call 000 if per plan or injury. 
• New symptoms or side-effects: write what/when; tell the IDC within 24 hours. 
After an incident (even small) 
• Write what happened in plain words (what we saw/heard/tried, what helped). 
• Tell the IDC within 24 hours; they’ll organise any review needed (some incidents 
must be reviewed within 72 hours). 
• Update the weekly plan so we practise the safer alternative next time. 
Boundaries that keep everyone safe 
• No cash handling or PINs unless the plan says so. 
• No posting photos/stories without permission. 
• Home is not a workplace: keep tasks purposeful, time-bound, and on the calendar. 
• Say “I don’t know” early. Ring the IDC. 
Remember: Your role is powerful. Ordinary places, reliable routines, clear words and patient 
coaching change lives. 

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Equity, First Nations Partnership and Access 
 
Purpose and scope 
 
This section makes equity operational so the standards hold everywhere and for everyone. It 
sets minimum requirements for First Nations partnership, language/communication access 
(CALD/Auslan/AAC), and rural/remote delivery (micro-hubs, tele-assessment, scholarships). 
It applies to all services and decision-making across home, community, education, health and 
justice interfaces. 
[See Service Model Standards (life in community); Workforce Standard  -  Integrated 
Disability Clinician (IDC); Data, Dashboards and Privacy.] 
 
Principles 
• Self-determination and partnership: First Nations peoples design and lead local 
approaches; community-controlled organisations are preferred partners where 
available. 
• Language justice: interpreters and accessible modes (Auslan, CALD languages, 
AAC) are built-in, not optional. 
• Cultural safety: services are delivered in ways that are physically, emotionally and 
spiritually safe; cultural needs are named and resourced. 
• Rural parity: people outside metro areas must be able to meet the same standard 
without higher burden or cost. 
• No parallel lives: equity is realised in ordinary places - schools, shops, workplaces, 
Country - not only in specialist settings. 
[See Definitions and Principles; Service Model Standards (life in community).] 
First Nations partnership standard 
 
Objective. Ensure First Nations people with cognitive disability receive supports that are 
culturally safe, locally governed and effective. 
Minimum requirements. 
• Partnership MOU: with a local First Nations community-controlled organisation (or 
regional body) that sets roles, decision rights, escalation pathways and payment for 
participation. 
• Cultural plan: one-page addendum to the person’s plan covering Country, kinship, 
language, protocol, decision-making preferences and who should be present at key 
meetings. 
• Cultural participation: offer on-Country supports where desired; schedule around 
cultural obligations; remunerate cultural brokerage. 
• Workforce: priority recruitment of First Nations IDC candidates; funded mentoring; 
recognition of cultural work as work. 
• Verification: DSC considers cultural context explicitly in Reasons & Weighting; use 
interpreters/cultural brokers at case conferences. 
[See Independent Verification Standard; Workforce Standard  -  IDC.] 

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Artefacts (appendices provide templates). Partnership MOU template; Cultural Plan 
template; cultural brokerage invoice template; participation register. 
[See Appendices (indexed).] 
Language and communication access standard (CALD/Auslan/AAC) 
Objective. Ensure everyone can understand, decide and attest in their preferred mode. 
Minimum requirements. 
• Interpreter booking SOP: available for all key interactions (planning, 72-hour 
learning reviews, DSC conferences, tribunal/OPA interfaces). Same-day urgent 
pathway documented. 
• Auslan & relay: access to qualified Auslan interpreters and relay services; video-
remote option where in-person is not feasible. 
• AAC-first practice: communication passports; symbol sets; yes/no and visual choice 
boards; supported conversation training for IDC. 
• Translated & Easy Read materials: Plain English + Easy Read versions for plans, 
summaries, sanctions notices and dashboard explanations; translated where relevant. 
• Two-party e-receipts: attestation via accessible modes (symbols/tap/audio prompts); 
role-based family visibility. 
[See Truth-by-Design Standard; Safety & Restrictive Practices Standard; Service 
Model Standards (life in community).] 
Artefacts. Interpreter request form; AAC kit checklist; translated/Easy Read pack index; 
attestation mode log. 
[See Appendices (indexed).] 
Rural and remote delivery standard 
Objective. Make the standards feasible and affordable outside metro areas. 
Minimum requirements. 
• Micro-hubs: pooled supervision/education sites serving small providers; shared 
examiners and interpreters; monthly outreach schedules published. 
• Tele-OSCE and tele-reviews: secure, scheduled remote stations/reviews; at least two 
in-person observations across the renewal cycle to validate field competence. 
• Scholarships & backfill: funded training time, travel and accommodation; backfill 
for small workforces. 
• Travel supports: time and mileage rules that do not penalise rural access; pooled 
transport options for community participation. 
• Minimum service levels: published response times for interpreter access, DSC 
observation and urgent reviews. 
[See Workforce Standard  -  IDC; Independent Verification Standard; Service Model 
Standards (life in community).] 
Artefacts. Micro-hub operating pack; tele-assessment protocol; scholarship terms; rural 
travel policy. 
[See Appendices (indexed).] 

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Minimum equity checks embedded in other standards 
• Workforce (IDC): equity modules (cultural safety, interpreters, AAC) are 
mandatory; observed competence includes one equity-focused station. 
• Safety: interpreters/cultural brokers are offered at 72-hour learning reviews; logs 
record whether used. 
• Truth-by-Design: e-receipt UI offers AAC/translations by default; exception 
handling does not penalise interpreter delays. 
• Independent Verification: reasons explicitly state how cultural/linguistic context 
was considered; publication redacts sensitive cultural detail. 
[See each named section.] 
Roles and responsibilities 
• Person/authorised representative: choose preferred language/communication and 
cultural supports; consent to sharing cultural information. 
• IDC: activate interpreter/AAC; use cultural plan; coach participation in ordinary 
places that matter locally. 
• Provider leadership: resource MOUs; schedule around cultural obligations; fund 
brokerage; maintain micro-hub participation. 
• Coordinator (independent): ensure interpreter bookings; manage switching to 
culturally safe providers if needed. 
• First Nations partners/cultural brokers: guide protocol; co-design local 
approaches; support reviews and conferences. 
• Commissioner/program owner: set equity targets; fund micro-hubs/scholarships; 
publish equity tiles; enforce minimum service levels. 
• DSC/Decision-makers: reflect cultural context in Reasons & Weighting; use 
interpreters; uphold privacy. 
[See Governance, Assurance and Risk; Independent Verification Standard.] 
Documentation and artefacts (publishable/auditable) 
• Signed Partnership MOU and annual activity log. 
• Cultural Plan (person-level) with consent record. 
• Interpreter/AAC utilisation records linked to key events (planning, reviews, hearings). 
• Micro-hub participation schedules; tele-OSCE/tele-review logs. 
• Scholarship awards and completion records. 
• Equity incident register (e.g., interpreter unavailable; cultural breach) with corrective 
actions. 
[See Data, Dashboards and Privacy.] 
Metrics and indicators (dashboards) 
• Access: interpreter utilisation rate; average time-to-interpreter; AAC use at key 
events. 
• First Nations partnership: number of active MOUs; participation hours; co-
designed initiatives delivered; satisfaction/feedback indicators. 
• Rural parity: micro-hub coverage; tele-OSCE completion; scholarship uptake; 
travel-related cancellations. 

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• Quality & safety: 72-hour review interpreter coverage; cultural plan presence; DSC 
cases noting cultural context. 
• Outcomes: presence/participation minutes in locally valued ordinary places; 
switching friction resolved within time limits. 
Public tiles are de-identified with suppression rules; person-level detail appears in 
family view. 
[See Data, Dashboards and Privacy; Evaluation & Continuous Learning.] 
Implementation (switch-on order) 
• 0-3 months: sign first Partnership MOUs; publish interpreter booking SOP; stand up 
two rural micro-hubs (one remote, one regional); add equity fields to e-receipts and 
review templates; fund initial scholarships. 
• 3-6 months: commence tele-OSCEs; publish first equity tiles (access and timeliness); 
run provider audits on interpreter usage; embed Cultural Plan template in accessible 
plan pack. 
• 6-12 months: expand micro-hubs; increase scholarship rounds; require equity station 
in OSCE; red-team scenario: interpreter failure during a sentinel event review. 
• 12-24 months: statewide micro-hub coverage; publish equity evaluation; adjust 
targets upward; integrate lessons into IDC curriculum refresh. 
[See Workforce Standard  -  IDC; Implementation Roadmap (Switch-On Order).] 
Risks and mitigations 
• Token partnership: enforce paid MOUs with decision rights; publish activity logs. 
• Interpreter shortages: pooled bookings via micro-hubs; remote options; priority 
queuing for reviews/hearings. 
• Cultural load on few people: rotate and reimburse brokers; build a wider bench 
through scholarships and mentoring. 
• Rural fatigue/costs: pooled supervision, shared assessment days, travel supports, and 
procurement preferences for compliant providers. 
• Privacy breaches of sensitive cultural information: strict consent flows; role-based 
access; redaction and suppression rules at publication. 
[See Data, Dashboards and Privacy; Governance, Assurance and Risk.] 
Data, Dashboards and Privacy 
 
Purpose and scope 
 
This section defines how information is captured, protected, and published so progress is 
visible and privacy-safe. It sets minimum data schemas (e.g., e-receipts, restraint 
timekeeping, IDC licensure), governance (DPIAs, access controls, audit logs), and 
publication rules (public tiles vs family view). It applies to all programs, providers and 
verification bodies. 
[See Truth-by-Design Standard; Safety & Restrictive Practices Standard; Workforce Standard  
-  Integrated Disability Clinician (IDC); Independent Verification Standard; Evaluation & 
Continuous Learning.] 

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Principles 
• Privacy by design. Collect the least data needed; store briefly; share narrowly; log 
everything. 
• Explainability. People can see what is held about them (family view) and why; 
public tiles explain methods and limits. 
• Interoperability. Open, versioned schemas and vendor-neutral APIs reduce burden 
and lock-in. 
• Equity. Accessible artefacts (Plain English, Easy Read, translations, AAC) are built 
in. 
• Security. End-to-end encryption in transit, encryption at rest, role-based access, 
immutable audit logs, key rotation and rapid revoke. 
• No black boxes. Analytics/AI must have published method notes; no opaque 
decisioning affecting rights or payments. 
Data domains (minimum sets) 
• Two-party e-receipts (who/role, what, when, where-category, outcome, attestation, 
exceptions). [See Truth-by-Design Standard.] 
• Safety timekeeping & reviews (type of restraint, start/end, minutes, alternatives, 72-
hour review outputs, fade plan pointers). [See Safety & Restrictive Practices 
Standard.] 
• Presence & participation tracker (minutes in ordinary places, roles/relationships 
formed, independence steps). [See Service Model Standards (life in community).] 
• IDC licensure & assessment (licence status, OSCE pass/renewal dates, supervision 
throughput; public fields only). [See Workforce Standard  -  IDC.] 
• Verification artefacts (DSC intake/turnaround, Reasons & Weighting publication 
status, Contradiction Matrix indicators). [See Independent Verification Standard.] 
• Exceptions & sanctions (roster-to-claim mismatches, resolution times, sanctions 
rung and duration). [See Truth-by-Design Standard.] 
• Equity and access (interpreter/AAC usage, micro-hub coverage, rural tele-OSCE 
completion). [See Equity, First Nations Partnership and Access.] 
Minimum schema rules (applies to every domain) 
• Open JSON schema with semantic field names and code lists; versioned (e.g., 
v1.2.0). 
• Identifiers. Person-level data uses pseudonymous IDs in system-of-record and is re-
identified only in the family view by role; public tiles never hold direct identifiers. 
• Timestamps & provenance. ISO 8601 timestamps with timezone; 
create/update/deletion events; source and method of capture noted. 
• Corrections. No destructive edits - immutable history with who/when/what changed. 
• Accessibility flags. Fields to record interpreter/AAC mode used. 
Appendices hold schema exemplars for e-receipt and dashboard tiles/suppression; 
this section is authoritative for rules. 
• Schema stub (events) 
event_type="two_key_decision" | event_id | person_psn | decision_class | 
first_key_role | first_key_id | second_key_role | second_key_id | independence_check 
(Y/N) | cosign_timestamp | tier0_flag (Y/N) | review_72h_timestamp | rw_note_ref | 
will_pref_ref | dsc_flag (Y/N) 

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DPIA (Data Protection Impact Assessment) 
• When required. For any new/changed data flow, dashboard, analytics model, or 
integration. 
• Contents (minimum). Purpose; lawful basis; data elements; recipients; 
storage/retention; access roles; risks; mitigations; test results; residual risk; sign-off. 
• Refresh. On material change or annually (whichever comes first). 
• Transparency. Publish a plain-language DPIA summary alongside public tiles. 
Access control and security 
• Role-based access (RBAC): least privilege by default; distinct views for families, 
providers, DSC/commissioners. 
• Authentication/authorisation: MFA for staff; short-lived tokens for APIs; session 
timeouts; conditional access for high-risk actions. 
• Encryption: TLS 1.2+ in transit; strong encryption at rest with key rotation; hardware 
security module (or managed KMS) for key custody. 
• Audit logging: append-only logs for reads, writes, exports and permission changes; 
tamper-evident; externally auditable. 
• Data location: declared jurisdictions; cross-border flows assessed in DPIA. 
• Backups & restoration: encrypted backups; regular restore tests; RTO/RPO 
documented. 
Publication model (family view vs public tiles) 
• Family view (role-based). Person-level receipts, review summaries, plans, switching 
status and progress. Export on request; redactions applied only where law requires. 
• Family view shows decision history. R&W short-form and will-and-preferences 
notes (role-based access); public tiles remain de-identified with suppression. 
• Public tiles (quarterly). De-identified indicators: e-receipt coverage/timeliness; 
exceptions & resolution; restrictive minutes/1,000 hours; 72-hour review compliance; 
fade-plan success; IDC licence/OSCE rates; DSC turnaround/publication; 
presence/participation minutes; equity measures; sanctions ladder distribution. 
• Suppression rules. Small-cell suppression (e.g., n<5), percentage masking for 
unstable rates, and k-anonymity thresholds; method notes published. 
• Release notes. Every publication includes a change log (what changed, why, expected 
impacts). 
 
Performance, KPIs & Public Dashboards (full specification) 
Purpose and audience 
Define exact tiles, fields, suppression rules and release cadence so families, providers and 
ministers can trust what’s published. Family view shows person-level truth; public tiles show 
de-identified trends with method notes. 
[See Publication model (family view vs public tiles).] 

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Tile catalogue (minimum quarterly set) 
• Integrity  -  e-receipt coverage & timeliness 
o Fields: period; coverage %; attested ≤48h %; ≤72h %; denominator; notes. 
o Source: receipt store. 
• Integrity  -  exceptions & resolution 
o Fields: E1-E8 rates; median days to resolve; >SLA proportion; ageing 
distribution. 
o Source: cross-check service. 
• Safety  -  restrictive minutes/1,000 hours 
o Fields: minutes; hours denominator; sentinel events; trend vs baseline. 
o Source: timekeeping log. 
• Safety  -  72-hour review & fade-plan 
o Fields: review compliance %; fade-plan success %; med reconciliation ≤72h 
%. 
o Source: review/fade datasets. 
• Workforce  -  IDC capability 
o Fields: licence rate; OSCE pass rate (first sit); renewal on time %; supervision 
throughput. 
o Source: licensure register/assessment. 
• Verification  -  DSC 
o Fields: cases received; median days to publish; calibration variance %; action 
completion %. 
o Source: DSC register. 
• Shared Decision (Two-Key) 
o two_key_coverage_pct  -  percentage of in-scope decisions with valid 
co-sign/quorum. 
o cosign_median_hours; cosign_p95_hours  -  time from first key to second 
key. 
o tier0_exception_rate_per_100_decisions  -  emergency pathway usage. 
o review_72h_coverage_pct  -  proportion of Tier-0 decisions reviewed ≤72h. 
o equity_lens_gap_pp  -  gap vs “all” by lens (First Nations, CALD, 
rural/remote, gender, age bands). 
o privacy: suppression n<5; rounding to nearest unit; publish change-logs. 
• Participation  -  minutes & roles 
o Fields: minutes in ordinary places; role counts (volunteer/trainee/paid); 
independence step-ups. 
o Source: presence/participation tracker. 
• Equity  -  access & rural parity 
o Fields: interpreter/Auslan utilisation; time-to-interpreter; micro-hub coverage; 
tele-OSCE completion. 
o Source: equity datasets. 
• Sanctions ladder 
o Fields: rungs distribution; time on rung; recurrence ≤12 months. 
o Source: sanctions register. 
• Governance  -  publication & incidents 
o Fields: on-time release %; corrections/addenda; S1/S2 incident count; 
suppression accuracy %. 

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o Source: release notes, incident logs. 
[See Truth-by-Design Standard; Safety & Restrictive Practices Standard; 
Workforce Standard  -  IDC; Independent Verification Standard; Equity.] 
Field standards & method notes (apply to all tiles) 
• Date keys: ISO 8601; quarter end date; timezone declared. 
• Denominators: shown and footnoted; include data completeness %. 
• Trend windows: show baseline (pre-pilot) and last 4 quarters; highlight method 
changes. 
• Confidence/uncertainty: display counts behind percentages; use bands where 
sampling is involved (e.g., calibration). 
• Method notes: public PDF/HTML each release describing sources, cleaning, 
exclusions, changes and impacts. 
• Right-of-reply: provider statement displayed where named per rules; 
expiry/rectification dates included. 
[See Data, Dashboards and Privacy.] 
Suppression & de-identification rules 
• Small-cell suppression: hide or pool where n < 5; display “ - ” with note. 
• k-anonymity: ensure k ≥ 10 per published cell after suppression/aggregation. 
• Dominance masking: where one provider/region >85% of a cell, pool to next 
geography band. 
• Rounding: round percentages to 1 decimal; counts to nearest 5 where needed. 
• Rare events: publish as pooled rolling 4-quarter totals. 
• Equity splits: only publish subgroup tiles where k-anonymity holds; otherwise 
include in method notes. 
[See Appendix S  -  Dashboard Tiles & Suppression Rules.] 
Accessibility & language 
• Plain English and Easy Read versions per tile set; large-type option; alt text for 
charts. 
• Translations for major CALD languages; Auslan explainer video per release. 
• Click-through from public tile → method note → release notes; family view has 
“What this means for me” tips. 
Release cadence & governance 
• Quarterly publication within 30 days of quarter end; release notes versioned. 
• Change control: any schema/method change listed with rationale and expected 
effect. 
• Freeze window: data freeze 7 days pre-publication; only critical fixes allowed. 
• Quality gates: suppression accuracy ≥99.5%; audit log completeness 100%; privacy 
incident S1/S2 = 0 to proceed. 
• Red-team stress: run at least one publishing drill per year (e.g., restraint spike, re-
identification test) and publish learnings. 
[See Governance, Assurance and Risk; Evaluation & Continuous Learning.] 

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Family view alignment 
• Drill-through: person can see their own receipts, reviews, plans and role steps; 
export on request. 
• Explainers: short per-tile notes on how their data contributes to aggregates; opt-out 
options where feasible and lawful. 
• Privacy: role-based access; immutable event history; no public exposure of person 
data. 
[See Publication model (family view vs public tiles).] 
API & event extensions (for tiles) 
• New events: tile.release.created, tile.release.corrected, tile.method.changed. 
• Dataset lineage stored per tile with hash of source extracts; audit log references 
included in release notes. 
[See Interoperability and APIs; Audit log spec.] 
Data lifecycle 
• Capture. In the flow (e-receipt at completion; timekeeping during or within 2 hours; 
trackers weekly). 
• Validation. Field-level checks; referential integrity (e.g., receipt↔claim↔roster); 
exception queues with SLAs. 
• Retention. Person-level data retained only as long as necessary; tile aggregates 
retained for trend analysis (e.g., 5 years). 
• Deletion. Right-to-erasure honoured where lawful; logs retain non-identifying event 
metadata. 
• Portability. Machine-readable exports for the person/authorised representative. 
Analytics and AI (allowed uses and limits) 
• Allowed. Descriptive and diagnostic analytics for dashboards and quality 
improvement; simple risk flags to route human review. 
• Not allowed. Fully automated adverse decisions affecting rights, payments or 
services; emotion inference; covert surveillance. 
• Method transparency. Publish model cards (purpose, data, limitations, fairness 
checks); opt-out where feasible without degrading essential safety. 
• Bias & drift checks. Quarterly fairness tests (e.g., by region, language, First Nations 
status where lawfully recorded); retraining governance. 
Operational guardrails (policy text) 
• No training on sensitive PII. No model training or fine-tuning on names, free-text 
case notes, clinical narratives or audio without explicit, documented consent and 
DPIA sign-off. 
• Shadow-mode before go-live. All new models run in shadow alongside human 
decisions for a defined period; performance and fairness must meet thresholds before 
any operational use. 
• Kill-switch & rollback. A technical and procedural kill-switch exists for every 
model; rollback to last known-good version is rehearsed and time-bound. 

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• Human-in-the-loop. Models may flag but cannot issue or enforce an adverse 
decision (access, eligibility, pricing, sanctions). A named human decision-maker 
owns each call. 
• Audit logs that matter. Inputs (hashed), outputs, overrides, user IDs and timestamps 
are retained under the Audit Log Spec with retention periods that enable independent 
review. 
• Transparency. Publish model cards (purpose, data sources, limits, fairness checks, 
update cadence) and provide an opt-out where feasible without degrading essential 
safety. 
• Quarterly fairness tests. Drift, calibration, and disparity checks by cohort (e.g., age, 
sex, CALD, rurality, First Nations status where lawfully recorded) with published 
method notes. 
Interoperability and APIs 
• Versioned, open APIs with test sandboxes and conformance suites. 
• Event model. Standard webhooks (receipt.created, restraint.logged, 
review.completed, dsc.published, sanction.changed). 
• Vendor neutrality. No mandatory proprietary SDKs; certification based on 
schema/API conformance, not brand. 
• Import adapters. Lightweight mappers for common rostering/claiming systems to 
cut integration cost. 
Assistive Technology (AT) & AAC Procurement Spec 
Purpose and scope 
Set minimum, vendor-neutral requirements so assistive technology and AAC tools enable 
person-first practice, capture truth in the flow, and protect privacy. Applies to mobile apps, 
web apps, devices and integrations used for e-receipts, communication, planning and 
tracking. 
[See Service Model Standards (life in community); Truth-by-Design Standard; Equity, First 
Nations Partnership and Access.] 
Functional requirements (minimum) 
• AAC-first: symbol boards, yes/no choice, sentence builders, photo/audio prompts; 
offline composition with later sync. 
• Attestation modes: tap, stylus signature, switch access, caregiver witnessed 
attestations; capture E7 Declined with reason. 
• Accessibility: meets WCAG 2.2 AA; large-type/Easy Read toggle; high-contrast 
mode; screen-reader tested; captioned micro-videos. 
• Multilingual: runtime language switch; UTF-8 throughout; on-device phrasebanks; 
Auslan/LSF video placeholders. 
• Offline-first: queue receipts/notes; show unsent badge; reconcile conflicts on sync 
with immutable history. 
• Family view linking: per-record share to family view with role-based access (no 
public endpoints). 
• Event hooks: must emit standard events (see Interoperability and APIs) for 
receipt.created, receipt.attested, review.completed. 

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Data & privacy requirements 
• DPIA required before deployment and on material change. 
• Data minimisation: coarse location categories only; no continuous GPS unless 
explicitly lawful and consented. 
• No biometrics or emotion inference for identity or consent. 
• Encryption: TLS 1.2+ in transit; platform encryption at rest; key rotation supported. 
• RBAC: least-privilege, session timeouts, device pin/biometric local unlock (biometric 
used only locally - never uploaded). 
• Audit log: append-only for creates/updates/attestations/exports; externally auditable. 
[See Data, Dashboards and Privacy.] 
Interoperability & conformance 
• Open schemas/APIs: must read/write the Minimum Two-Party E-Receipt JSON 
and tile schemas; version negotiation required. 
• Conformance tests: supplier passes public test suites (positive/negative cases, 
accessibility checks, offline/merge tests) and provides artefact reports. 
• Import adapters: vendor supplies mappers for common roster/claim systems without 
extra licence fees. 
• No lock-in: data export (JSON/CSV + attachments) within 10 business days of 
notice; perpetual read access to person records for family view. 
Security & reliability (SLOs) 
• Uptime: ≥99.5% monthly (excluding planned maintenance with 7-day notice). 
• Incident response: acknowledge S1/S2 within 4h; fix/contain within 72h; issue post-
incident report. 
• Pen-testing: annual independent test; criticals fixed within 30 days. 
• Mobile MDM: support standard device management; remote wipe on loss. 
[See Incident response & red-team tests.] 
Procurement & licensing 
• Pricing clarity: per-seat and per-org caps; non-profit/rural discounts; no charge for 
API access or conformance kits. 
• IP & exit: configurations/templates produced for the program are open for reuse; exit 
plan tested before go-live. 
• Localisation: First Nations language packs and CALD priorities scheduled; 
community co-design remunerated. 
• Ethical terms: ban dark-patterns; ban data resale/advertising; declare any sub-
processors and data locations. 
Evaluation & pilot 
• Sandbox trial: 4-6 weeks; success = conformance pass, DPIA sign-off, accessibility 
verification, user task success ≥90%. 
• Red-team drill: simulate offline outage and sync recovery; verify integrity and audit 
logging. 
• User panel: families, IDC, interpreters/Auslan, rural sites; defects tracked to closure. 

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Incident response & red-team tests 
• Severity tiers. S1 (person-identifiable data exposure), S2 (availability breach), S3 
(integrity/reporting issue). 
• SLA. Acknowledge within 24h, contain within 72h, notify affected parties/regulators 
per law, publish a post-incident report. 
• Red-team schedule. Annual privacy drills (lost device, access abuse), fraud ring 
simulation, and restraint-spike publication stress test. 
• Lessons learned. Actions tracked on dashboards with due dates. 
Where to get help / Artefacts & Templates (appendices index) 
• DPIA template (long form + plain-language summary). 
• Minimum Two-Party E-Receipt JSON Schema (with accessibility fields). 
• Dashboard tiles & suppression rules (field list; thresholds; method notes). 
• Audit log spec (events, fields, retention). 
• Release notes template (versioning, changes, impacts). 
Appendices store the templates; this section is the source of truth. 
Metrics and indicators (for dashboards) 
• Data quality: completeness, timeliness, validation pass rate, duplicate rate. 
• Privacy & security: DPIA coverage, access exception rate, audit log completeness, 
incident count by tier (target S1/S2 = zero). 
• Publication: on-time release rate, suppression accuracy, number of method-note 
updates. 
• Usefulness: family-view sign-ins, provider dashboard downloads, support-plan 
updates triggered by tiles. 
• Equity: interpreter/AAC fields recorded; micro-hub coverage in data; rural timeliness 
parity. 
[See Evaluation & Continuous Learning.] 
Implementation (switch-on order) 
• 0-3 months: publish schemas and DPIA template; stand up audit log; enable family 
view for e-receipts; pilot two public tiles (coverage, restrictive minutes). 
• 3-6 months: add exception/resolution tiles; release suppression rules + method notes; 
run first privacy drill; API sandbox opens. 
• 6-12 months: expand to full indicator set; independent audit of pipeline integrity; 
start model-card process for any analytics; publish red-team results. 
• 12-24 months: statewide tiles; longitudinal trend analysis; integrate DSC publication 
metrics; external evaluation of dashboard impact. 
[See Implementation Roadmap (Switch-On Order).] 
Risks and mitigations 
• Re-identification risk in small communities: strict suppression; region-pooling 
where necessary; publish method notes. 

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• Data burden on small providers: shared adapters, micro-hub technical support, 
focus on minimal fields. 
• Metric gaming: triangulate with DSC/file-vs-field checks; rotate indicators; publish 
anti-gaming notes. 
• Security drift: quarterly access reviews; key rotation; automated anomaly detection; 
external audits. 
• Misinterpretation of tiles: plain-language legends, uncertainty bands, and context 
notes; provider right-of-reply where named by rule. 
Implementation Roadmap (Switch-On Order) 
 
How to use this roadmap 
 
This roadmap delivers the standards quickly, safely, and at manageable scale. It uses existing 
powers (practice notes, procurement terms, program rules) rather than waiting for omnibus 
legislation. Each phase has deliverables, QA & privacy gates (go/no-go), owners, and public 
signals. 
[See Workforce Standard  -  Integrated Disability Clinician (IDC); Safety & Restrictive 
Practices Standard; Truth-by-Design Standard; Independent Verification Standard; Data, 
Dashboards and Privacy.] 
 
Pilot design (where we start and why) 
• Sites (minimum 4): two metro; two regional/rural (one remote). 
• Provider mix: at least one small (<40 FTE), one medium (40-200 FTE), one large 
(>200 FTE). 
• Populations: include children (incl. developmental delay), adolescents, adults (incl. 
ABI). 
• Equity anchors: at least one First Nations partnership MOU in a pilot; 
interpreters/Auslan capacity tested in all pilots. 
• Interfaces covered: school/education, primary/acute health, justice interface (one 
site), community participation. 
• Instruments used: practice notes; procurement variations; program rule updates (no 
new Act required). 
• Success definition: phase gates below all PASS; dashboards publish on schedule; 
families report increased confidence. 
Phase 1  -  0 to 3 months (Switch-on foundations) 
 
Deliverables 
• Publish: IDC curriculum map, EPA logbook, OSCE blueprint; Restraint Hierarchy 
& Timekeeping; 72-hour review template; Fade plan template. 
• Stand up: DSC unit; Reasons & Weighting and Contradiction Matrix templates; 
DSC SOP. 
• Issue Tribunal Practice Note (Two-Key) and OPA/OPG Investigations Code 
addendum. 
• Stand up IPP with 72-hour pairing SLA; tele-co-sign ready. 

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• Publish templates: R&W (short); Will-and-Preferences; Tier-0 Log & 72-Hour 
Review; DSC Calibration Memo. 
• Data: release e-receipt schema; enable family view for e-receipts; stand up 
immutable audit log. 
• Dashboards: launch two public tiles (e-receipt coverage; restrictive minutes/1,000 
hours). 
• Equity & rural: sign first First Nations MOU; open two micro-hubs (one regional, 
one remote); interpreter booking SOP. 
• Policy levers: issue practice notes; add procurement terms (sanctions ladder, 
switching protocol); update program rules. 
• Change kit: Plain English/Easy Read packs for families; provider onboarding 
checklists; ministerial brief. 
QA & Privacy Gates (Go/No-Go) 
• DPIA approved for e-receipt + safety pipelines (Data & Privacy owner: PASS). 
• DSC SOP - tested on two sentinel cases (Independent Verification owner: PASS). 
• OSCE pilot stations trialled with acceptable inter-rater reliability (Workforce owner: 
PASS). 
• Audit log events verifiably append-only (Data & Privacy owner: PASS). 
Owners 
• Program Owner/Commissioner (overall), Workforce Standards Authority, DSC Unit, 
Data & Privacy Office, Pilot Providers, First Nations partner. 
Public signals 
• First tiles live with method notes; publication cadence and suppression rules 
documented. 
Phase 2  -  3 to 6 months (Operate, measure, adjust) 
 
Deliverables 
• First OSCE sittings; RPL portal live; conditional IDC licences issued where bridging 
applies. 
• Roster-to-claim cross-checks live for existence & timing; exception queue (E1-E3) 
with SLAs. 
• 72-hour learning reviews mandatory; fade-plan compliance monitored; hospital/ED 
handover & med reconciliation sheet in use. 
• Pilot metro + rural; hit coverage ≥90%, median ≤48h by month 6; publish 
de-identified tiles. 
• Activate anti-collusion rotation checks and DSC sampling. 
• DSC coverage expands to integrity and pattern-risk triggers; double-rating on ≥10% 
cases. 
• Switching protocol enforced; Exit & Entry Data Set issued within set time limits. 
• Equity: interpreter/AAC fields recorded in all key events; scholarship round 1 for 
rural IDC candidates. 

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QA & Privacy Gates 
• E-receipt coverage ≥70% of eligible supports in pilots; 48/72-hour attestation 
≥80% (Truth-by-Design owner: PASS). 
• 72-hour review compliance ≥85%; sentinel events escalated within 24h (Safety 
owner: PASS). 
• DPIA for cross-check pipeline approved; no S1/S2 incidents (Data & Privacy owner: 
PASS). 
Owners 
• Same as Phase 1, plus Procurement & Contracts for sanctions ladder alignment. 
Public signals 
• Add tiles: exception rate & age; 72-hour review compliance; OSCE pass rates. 
Phase 3  -  6 to 12 months (Scale and calibrate) 
 
Deliverables 
• Full exception set (E1-E8) with triage; role/location variance checks; provider 
monthly variance reviews. 
• Sanctions ladder operational with publication rules; provider right-of-reply flow. 
• Tele-OSCEs (defined stations); at least two in-person observations per candidate in 
renewal cycle. 
• DSC method notes published; calibration report on inter-rater reliability. 
• Presence & participation tracker live; community role-building pathways 
(volunteer → trainee → paid). 
• Micro-hubs expand; scholarship round 2; equity station added to OSCE. 
• Red-team tests: fraud ring simulation; restraint-spike publication stress test; 
interpreter failure during sentinel event review. 
• Extend to priority cohorts; quarterly peer calibration; independent evaluation begins. 
QA & Privacy Gates 
• E-receipt coverage ≥85%; exception SLA compliance ≥90% (Truth-by-Design 
owner: PASS). 
• Restrictive minutes/1,000 hours trending down; fade-plan success trending up 
(Safety owner: PASS). 
• DSC turnaround median ≤21 days; publication within 21 days ≥85% (Independent 
Verification owner: PASS). 
• Suppression accuracy ≥99.5% across tiles; no S1/S2 privacy incidents (Data & 
Privacy owner: PASS). 
Owners 
• Program Owner, Workforce Standards Authority, DSC Unit, Data & Privacy Office, 
Equity Lead, Micro-hub Leads. 

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Public signals 
• Add tiles: DSC turnaround & variance; presence/participation minutes; sanctions 
distribution; equity access measures. 
Phase 4  -  12 to 24 months (Statewide adoption and external evaluation) 
 
Deliverables 
• Legacy “Direct Care” titles sunset; all frontline roles aligned to IDC with renewal 
policy in force. 
• Statewide dashboards; longitudinal trends published with method updates. 
• Independent evaluation (safety outcomes, participation, ROI, appeals); public report 
and response plan. 
• Standards refresh (sunset/retain/revise) via Evaluation & Continuous Learning 
cycle. 
• Procurement preferences for providers meeting standards; switching friction audits; 
rural parity review. 
QA & Privacy Gates 
• Target attainment (illustrative minimums): 
o OSCE pass ≥85% first-sit; renewal on time ≥90%. 
o 72-hour review compliance ≥95%; fade-plan success upward trend sustained. 
o E-receipt coverage ≥95%; exception ageing >10 business days <5%. 
o DSC publication within 21 days ≥90%; appeal/overturn rate stable or 
decreasing. 
o Presence/participation minutes +20-30% vs baseline; equity gaps closing. 
• Privacy: zero S1/S2 incidents; annual external audit clean report. 
Owners 
• Program Owner; central agencies (finance/treasury) for ROI review; independent 
evaluator. 
Public signals 
• Full indicator set; evaluation summary; next-cycle targets. 
Cross-cutting QA & governance (always on) 
• Gate reviews chaired by Program Owner with Data & Privacy, Workforce, Safety, 
DSC, Equity and Procurement owners; families/First Nations partner invited. 
• Risk register with trigger thresholds and escalation paths. 
• Issue management: root-cause, action owner, due date, close-out verification; 
publish improvement themes each quarter. 
• Whistleblowing and retaliation sanctions enforced. 
[See Governance, Assurance and Risk.] 

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Critical path & dependencies 
• People: examiner pool & supervisors for OSCE; DSC staffing; interpreter and AAC 
capacity; micro-hub educators. 
• Tech: e-receipt & cross-check pipeline; dashboards; audit log; API adapters for 
common roster/claim systems. 
• Policy: practice notes, procurement clauses, program rules; sanctions ladder policy; 
publication & suppression rules. 
• Equity: Partnership MOUs; scholarship funding; tele-OSCE infra. 
• Change: provider onboarding; family communication; media & ministerial comms. 
Roles and RACI (summary) 
• Program Owner/Commissioner (A/R): delivery, gates, publication cadence. 
• Workforce Standards Authority (R): IDC curriculum, OSCE, renewal, examiner 
calibration. 
• DSC Unit (R): verification SOP, artefacts, publication of reasons, calibration. 
• Data & Privacy Office (R): schemas, DPIAs, audit logs, suppression rules, red-team 
tests. 
• Procurement & Contracts (R): sanctions ladder terms, switching, provider 
obligations. 
• Pilot Providers (R): implement standards, data capture, local QA. 
• First Nations Partners & Equity Lead (R): MOUs, cultural safety, 
interpreter/Auslan/AAC enablement. 
• Families/Representatives (C/I): co-design artefacts, review family view, feedback 
loops. 
(C=Consulted, I=Informed, R=Responsible, A=Accountable) 
Communications plan (minimum) 
• Families: Plain English/Easy Read explainer, what to expect this month/quarter, how 
to view family dashboards, how to switch. 
• Frontline/Providers: “What changes now” bulletins, OSCE calendar, e-receipt how-
to, exception SLAs, sanctions policy. 
• Decision-makers: DSC method notes, Reasons & Weighting exemplars, publication 
schedule. 
• Ministers/Central agencies: milestones, risks, ROI snapshots, media lines for 
dashboard releases. 
Finance & ROI alignment (spend to save) 
• Costed bundles: OSCE/assessment throughput, DSC operations, micro-hubs, 
interpreter pool, data pipelines. 
• Returns tracked: avoided hospital/ED events; reduced re-work/appeals; improved 
market mix; reduced integrity leakage. 
• Workbook cadence: quarterly updates; sensitivity ranges; release notes. 
[See Finance & ROI Case; Data, Dashboards and Privacy.] 

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Red-team & rehearsal calendar 
• Quarterly: fraud ring; data breach; provider failure & mass switching; restraint-
spike. 
• Outputs: public method notes; improvements logged and closed within set 
timeframes. 
[See Governance, Assurance and Risk; Safety & Restrictive Practices Standard; 
Truth-by-Design Standard.] 
Exit criteria (when a pilot becomes business-as-usual) 
• All phase gates PASS two quarters in a row. 
• Indicators stable or improving without extraordinary support. 
• Independent evaluator confirms attributable gains (safety, participation, integrity, 
equity). 
• Procurement terms embedded; training/assessment throughput sustainable. 
Finance & ROI Case 
Purpose and frame 
This section explains how money, risk and value move through the program. It provides a 
transparent, auditable approach for ministers, central agencies and providers to see where 
costs land, where benefits accrue, and how the standards convert into fiscal and societal 
returns. It is designed to plug straight into the ROI workbook and dashboards. 
[See Implementation Roadmap (Switch-On Order); Data, Dashboards and Privacy; 
Evaluation & Continuous Learning.] 
What value we count (benefit classes) 
• Avoided harm (fiscal): fewer ED presentations, hospital bed-days, ambulance call-
outs, medication misadventures, and damage/insurance events attributable to poor 
practice. 
• Reduced re-work (fiscal/operational): fewer repeats/appeals; lower tribunal/public 
advocate processing time; fewer incident re-investigations; lower duplicate 
assessments. 
• Integrity uplift (fiscal): prevented error/fraud via two-party e-receipts and roster-to-
claim cross-checks; sanctions ladder deters persistent leakage. 
• Quality & participation (economic/wellbeing): more minutes in ordinary places; 
increased role/relationship formation; progression to training/employment; carer 
confidence and hours returned to work/education. 
• Workforce stabilisation (operational): higher competence, reduced turnover, less 
agency backfill, fewer critical incidents per 1,000 hours. 
Each benefit is paired with a data source, unit cost proxy, and an 
attribution/“cashability” rating (cash-releasing, near-cash, non-cash wellbeing). 

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What it costs (investment bundles) 
• IDC pathway: curriculum, supervision, OSCE circuits, licensure register, examiner 
calibration. 
• Safety: restraint timekeeping enablement, 72-hour learning review and fade-planning 
capacity, handover/reconciliation tooling. 
• Truth-by-Design: e-receipt capture, cross-check service, exception queues, sanctions 
administration, release notes. 
• Independent Verification (DSC): staffing, field observation travel, artefact 
production, publication. 
• Equity & rural parity: First Nations partnership MOUs, interpreter/Auslan/AAC 
access, micro-hubs, tele-OSCEs, scholarships, travel supports. 
• Data & privacy: schemas, APIs, immutable audit log, dashboards, DPIAs, red-team 
tests. 
• Change & comms: Plain English/Easy Read packs, provider onboarding, family 
help-desk. 
Cost-benefit method (how the workbook calculates) 
• Time horizon: base 24 months (pilot+scale), with 60-month view for persistence of 
effects. 
• Discount rate: Treasury default (set in the workbook parameter sheet). 
• Counterfactual: “business as usual” curves per site/region (pre-pilot trend + 
seasonality) with matched controls where available. 
• Attribution: difference-in-difference where controls exist; otherwise segmented 
before/after with sensitivity ranges and DSC-verified event logs (file-vs-field). 
• Cashability ladder: 
1. Cash-releasing (e.g., bed-days avoided beyond occupancy thresholds). 
2. Near-cash (e.g., reduced agency backfill, fewer re-investigations). 
3. Non-cash wellbeing (QOL, participation, carer confidence). 
• Publication cadence: quarterly tiles (high-level), annual ROI brief (with method 
notes and ranges), and a technical annex for evaluators. 
Core formulas (transparent and auditable) 
Let ttt index months, iii index pilot sites, and δ\deltaδ denote measured change vs 
counterfactual. 
1) Avoided ED presentations 
EDavoided(t,i)=(EDratecf(t,i)-
EDrateobs(t,i))×exposed_population(t,i)\text{ED}_\text{avoided}(t,i)=\left(\text{ED}_\text{
rate}^{\text{cf}}(t,i)-\text{ED}_\text{rate}^{\text{obs}}(t,i)\right)\times 
\text{exposed\_population}(t,i)EDavoided(t,i)=(EDratecf(t,i)-EDrateobs
(t,i))×exposed_population(t,i) 
BenefitED(t,i)=EDavoided(t,i)×unit_costED\text{Benefit}_\text{ED}(t,i)=\text{ED}_\text{a
voided}(t,i)\times \text{unit\_cost}_\text{ED}BenefitED(t,i)=EDavoided(t,i)×unit_costED  
2) Avoided bed-days from restraint/med errors 

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Daysavoided(t,i)=δRestrictiveMinutes(t,i)×βdays/minute\text{Days}_\text{avoided}(t,i)=\del
ta\text{RestrictiveMinutes}(t,i)\times \beta_\text{days/minute}Daysavoided
(t,i)=δRestrictiveMinutes(t,i)×βdays/minute 
Benefitbed(t,i)=Daysavoided(t,i)×unit_costbedday\text{Benefit}_\text{bed}(t,i)=\text{Days}
_\text{avoided}(t,i)\times \text{unit\_cost}_\text{bedday}Benefitbed(t,i)=Daysavoided
(t,i)×unit_costbedday  
3) Integrity uplift 
Benefitintegrity(t,i)=(Leakagecf-
Leakageobs)×claim_value\text{Benefit}_\text{integrity}(t,i)=\left(\text{Leakage}^{\text{cf}
}-\text{Leakage}^{\text{obs}}\right)\times \text{claim\_value}Benefitintegrity
(t,i)=(Leakagecf-Leakageobs)×claim_value  
4) Reduced re-work/appeals 
Benefitrework(t,i)=δCases(t,i)×time_per_case×unit_costFTE\text{Benefit}_\text{rework}(t,i
)=\delta\text{Cases}(t,i)\times \text{time\_per\_case}\times 
\text{unit\_cost}_\text{FTE}Benefitrework(t,i)=δCases(t,i)×time_per_case×unit_costFTE  
5) Workforce stabilisation 
Benefitturnover(t,i)=δTurnover(t,i)×replacement_cost_per_FTE\text{Benefit}_\text{turnover
}(t,i)=\delta\text{Turnover}(t,i)\times \text{replacement\_cost\_per\_FTE}Benefitturnover
(t,i)=δTurnover(t,i)×replacement_cost_per_FTE  
6) Participation uplift (economic proxy) 
Benefitparticipation(t,i)=δMinutesInCommunity(t,i)×value_per_min\text{Benefit}_\text{part
icipation}(t,i)=\delta\text{MinutesInCommunity}(t,i)\times 
\text{value\_per\_min}Benefitparticipation(t,i)=δMinutesInCommunity(t,i)×value_per_min  
Parameters live in the workbook’s Assumptions sheet with low/base/high ranges; dashboards 
feed the δ\deltaδ metrics directly. 
7) Program NPV and BCR 
NPVBenefits=∑t=0T∑iBenefits(t,i)(1+r)t;NPVCosts=∑t=0T∑iCosts(t,i)(1+r)t\text{NPV}_\t
ext{Benefits}=\sum_{t=0}^{T}\frac{\sum_i \text{Benefits}(t,i)}{(1+r)^t}\quad;\quad 
\text{NPV}_\text{Costs}=\sum_{t=0}^{T}\frac{\sum_i 
\text{Costs}(t,i)}{(1+r)^t}NPVBenefits=t=0∑T(1+r)t∑iBenefits(t,i);NPVCosts=t=0∑T
(1+r)t∑iCosts(t,i) BCR=NPVBenefitsNPVCosts;NetBenefit=NPVBenefits-
NPVCosts\text{BCR}=\frac{\text{NPV}_\text{Benefits}}{\text{NPV}_\text{Costs}}\quad;\
quad \text{NetBenefit}=\text{NPV}_\text{Benefits}-
\text{NPV}_\text{Costs}BCR=NPVCostsNPVBenefits;NetBenefit=NPVBenefits-NPVCosts  
Inputs and sources (traceability) 
• Safety: restrictive minutes/1,000 hours; 72-hour review compliance; fade-plan 
success; med reconciliation completion. 

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• Integrity: e-receipt coverage; exception rates (E1-E8); sanctions ladder 
rungs/duration; resolution times. 
• Workforce: IDC licence/renewal; OSCE pass; supervision throughput; turnover; 
agency backfill hours. 
• Verification: DSC turnaround; publication timeliness; calibration variance; action 
close-out. 
• Participation: minutes in ordinary places; role/relationship counts; switching friction 
metrics. 
• Equity & rural: interpreter/AAC utilisation; micro-hub coverage; tele-OSCE 
completion. 
Each input cites its system-of-record (receipt store, timekeeping log, DSC register, 
licensure register, tracker, audit log). Family view provides micro-level evidence; 
public tiles publish aggregate indicators with suppression rules. 
Assumptions register (editable ranges) 
• Unit costs: ED triage/presentation, bed-day, ambulance call-out, tribunal hour, 
supervisory hour, replacement cost per FTE, exception handling hour. 
• Effect sizes: expected % reduction in ED/bed-days tied to restraint reduction; % 
leakage reduction from cross-checks; % re-work drop from DSC; % turnover change 
from IDC pathway; minutes-in-community uplift from Service Model Standards. 
• Lag structure: months from training to OSCE pass; from DSC referral to action; 
from switching to presence uplift. 
• Cashability: fraction of each benefit that converts to cash-releasing vs near-cash vs 
wellbeing. 
• Discount rate & inflation: set globally; workbook calculates real and nominal series. 
Worked example (illustrative flow; populate with local values) 
• Input: Restrictive minutes fall by Δ = 25% over 6-12 months in pilots; med 
reconciliations within 72h rise to ≥90%. 
• Link: Historical correlation and clinical review suggest βdays/minute = x.xxE-3 bed-
days per restricted minute (set locally; validated by DSC clinical method notes). 
• Result: Avoided bed-days = Δminutes × β × unit_cost_bedday → fiscal benefit; 
expected ED reduction compounds this result. 
• Integrity: E1/E2 exceptions drop by Δ = 60% post-pilot; leakage proxy = exception 
value × unresolved proportion; sanctions ladder reduces recurrence by Δ = 40%. 
• Net effect: Benefits rise while costs front-load (IDC training, DSC stand-up, data 
pipelines). BCR crosses >1 once coverage thresholds are hit (see Implementation 
Roadmap gates). 
Sensitivity and scenario testing 
• Three-box ranges: LOW/BASE/HIGH for unit costs and effect sizes; tornado chart 
in the workbook highlights the top five drivers (typically bed-day unit cost, leakage 
reduction %, OSCE throughput, sanction recurrence, turnover delta). 
• Time-to-value scenarios: Conservative (slow uptake), Base (roadmap on time), 
Stretch (fast rural parity + early sanctions signal). 
• Equity lens: stratify results by rural/metro and interpreter/AAC use to ensure gains 
are not concentrated in easier contexts. 

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• Publication: quarterly tiles show base case; annual annex publishes sensitivity ranges 
and driver attribution. 
Governance, assurance and publication 
• Owner: Program Owner/Commissioner with Finance/Treasury liaison. 
• Method notes: published with each quarterly/annual release (changes, parameter 
shifts, rationale). 
• Audit: annual external review of data lineage (capture→tile→ROI) and parameter 
reasonableness; DSC method notes validate causal links used in benefits. 
• Right-of-reply: providers can submit factual corrections; versioned ROI releases 
show amendments; family view remains authoritative at person level. 
• Ethics & privacy: DPIAs for all new flows; suppression rules applied to ROI tiles; 
no person-identifiable data in public outputs. 
Distributional impacts (who benefits, who pays) 
• Families/people: more presence in ordinary places; fewer crises; easier switching; 
clearer signals of provider quality. 
• Providers: up-front costs for competence and integrity, offset by market advantage 
for meeting the standard. 
• System: reduced acute spend and re-work; better information for procurement and 
program design. 
• Regions: micro-hubs and scholarships rebalance access; tele-OSCEs reduce travel 
waste; measure rural parity in tiles. 
Interfaces with other sections 
• Workforce (IDC): costs (curriculum, OSCE) and benefits (capability, turnover) feed 
ROI; licensure fields populate tiles. 
• Safety: restrictive minutes and learning-review compliance drive avoided harm 
estimates. 
• Truth-by-Design: integrity benefits and sanctions ladders shift provider mix and 
leakage. 
• Independent Verification: re-work/appeal reductions and publication costs are 
measured; DSC outcomes are a quality lever. 
• Service Model Standards: participation minutes and role formation deliver 
wellbeing/economic proxies. 
• Data & Privacy: schemas, audit logs, suppression and DPIAs underpin all ROI 
calculations. 
Metrics (dashboard alignment) 
• Finance tiles (quarterly): avoided harm proxy ($), integrity uplift ($), re-work 
reduction ($), IDC throughput/costs ($), DSC cost/benefit ratio, net program cost ($), 
net benefit ($), BCR. 
• Operational glue: coverage thresholds (e-receipt, 72-hour reviews, OSCE), 
exception SLA performance, sanctions recurrence, turnover. 
• Equity: rural parity cost per outcome; interpreter/AAC cost per outcome; distribution 
of benefits by region. 

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Risks and mitigations 
• Over-claiming benefits: DSC verifies causal chains; external audit of assumptions; 
conservative ranges published. 
• Under-counting near-cash benefits: track re-deployable capacity explicitly (e.g., 
staff time released). 
• Data gaps/quality drift: validation rules, exception queues, immutable logs; red-
team tests. 
• Perverse incentives: publish method notes; triangulate with quality/outcome 
indicators; sanctions for gaming. 
• Equity blind spots: require stratified reporting; adjust targets where rural/First 
Nations contexts face structural barriers. 
Governance, Assurance and Risk 
 
Purpose and scope 
 
This section names who owns what, how assurance happens, and how risks are surfaced and 
acted on without delay. It aligns decision rights with accountability, integrates the sanctions 
ladder, defines escalation, and embeds whistleblowing, audit and red-team practices across all 
standards. 
[See Truth-by-Design Standard; Independent Verification Standard; Implementation 
Roadmap (Switch-On Order); Data, Dashboards and Privacy.] 
 
Governance model (who decides, who delivers, who checks) 
• Program Owner/Commissioner (Accountable): sets targets, approves phase gates, 
issues practice notes/program rules, owns publication cadence for dashboards and 
releases the quarterly “state of the standards” brief. 
• Workforce Standards Authority (Responsible): owns the IDC standard, 
curriculum, OSCEs, licensure/renewal policy, examiner calibration and de-rostering 
rules. [See Workforce Standard  -  IDC.] 
• Safety Owner (Responsible): owns the Restraint Hierarchy & Timekeeping, 72-hour 
learning review, fade plans, hospital/ED handover & medication reconciliation. [See 
Safety & Restrictive Practices Standard.] 
• Truth-by-Design Owner (Responsible): operates the e-receipt and roster-to-claim 
cross-checks, manages exception SLAs and the sanctions ladder, and publishes 
integrity method notes. [See Truth-by-Design Standard.] 
• DSC Unit (Independent): provides neutral verification, maintains Reasons & 
Weighting and Contradiction Matrix templates, and publishes plain-English reasons. 
[See Independent Verification Standard.] 
• Roles for Two-Key Guardianship: 
o Guardians/MPG: co-sign/quorum; maintain independence record; use R&W 
short form. 
o IPP Operator: conflict screening, pairing within 72h, rotation ledger, QA 
sampling. 
o Tribunal/OPA/OPG: practice note/code; Interim Pause powers; quarterly 
publication; 90-day sweep of legacy sole-guardian orders. 

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o DSC Panel: calibration on triggers; publish method; quarterly peer-review. 
• Data & Privacy Office (Independent): owns schemas, DPIAs, suppression rules, 
immutable audit logs, API standards and privacy/security incident response. [See 
Data, Dashboards and Privacy.] 
• Equity Lead (Responsible): owns First Nations MOUs, interpreter/Auslan/AAC 
access standards, micro-hubs, tele-OSCE protocols and scholarships. [See Equity, 
First Nations Partnership and Access.] 
• Procurement & Contracts (Responsible): embeds standards into contracts, runs 
compliance checks, applies consequences, and aligns provider incentives with quality 
signals. 
• Providers (Responsible): implement standards, supervise IDC practice, close 
corrective actions, and ensure switching protocol and data capture are met. 
• Families/Authorised representatives (Consulted/Informed): participate in 
decisions, receive family-view dashboards, and have clear right-of-reply channels. 
Lines of assurance (how we know it’s working) 
• Line 1  -  Delivery controls: built-in checks (e-receipts, timekeeping, exception 
queues, supervision and observation, OSCEs, switching SLAs). 
• Line 2  -  Independent oversight: DSC file-vs-field verification, Data & Privacy 
audits of logs/DPIAs, Procurement compliance reviews, Equity access audits 
(interpreters, micro-hubs, scholarships). 
• Line 3  -  External assurance: periodic external audits (privacy/security, data 
lineage, ROI methods), and independent evaluation of outcomes. 
Assurance evidence is published through dashboards, method notes and release notes 
with suppression rules where required. 
Decision rights and escalation 
• Go/No-Go gates: the Program Owner chairs gate reviews; each standard owner 
presents QA results (PASS/FAIL) for their domain. [See Implementation Roadmap 
(Switch-On Order).] 
• Material risk decisions: safety sentinel events, sanctions at rungs 3-5, and 
publication pauses require joint sign-off by the relevant owner and Program Owner; 
DSC advice is tabled where applicable. 
• Escalation clocks: unresolved exceptions ageing beyond SLA (integrity), overdue 
72-hour reviews (safety), and non-publication beyond cadence (data) auto-escalate to 
owners at 5/10 business days, then to the Program Owner at 15 business days. 
Privacy/AI conformance  -  gate criteria 
• DPIA completed and signed for any AI/analytics use that touches access, eligibility, 
pricing or safeguards. 
• Shadow-mode results meet preset accuracy/fairness thresholds; external red-team 
issues closed. 
• Kill-switch and rollback demonstrated; on-call ownership rostered. 
• Audit-log fields validated against the spec; retention and access controls tested. 
• Plain-English model card published (or appended), with contact for queries. 

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Sanctions ladder (governance integration) 
• Ownership: Truth-by-Design Owner proposes rung; Procurement applies contract 
terms; Program Owner confirms publication where rules allow; provider right-of-
reply is recorded. 
• Linkages: repeat patterns trigger DSC verification; outputs feed Reasons & 
Weighting; corrective actions are tracked on dashboards until closed. 
• Expiry: public listing sunsets on rectification dates; recurrence within 12 months re-
opens the listing and triggers a higher rung. 
• Breach: missing/invalid co-sign → corrective plan; temporary pause; repeat 
breaches → panelisation or guardian swap; serious/knowing breach → referral. 
• Anti-collusion breach → freeze pairing; external moderation; publication where 
lawful. 
[See Truth-by-Design Standard; Independent Verification Standard.] 
Risk management (register, thresholds, actions) 
 
Risk classes and examples: 
• Safety & rights: restraint spikes; missed 72-hour reviews; medication reconciliation 
gaps. 
• Integrity: e-receipt coverage dips; exception ageing; suspected fabrication. 
• Privacy & security: S1/S2 incidents; audit-log gaps; suppression failures. 
• Workforce throughput: OSCE capacity shortfalls; supervision shortages; renewal 
delays. 
• Equity & access: interpreter shortages; micro-hub outages; rural switching delays. 
• Data quality: schema drift; late or incomplete feeds; interoperability failures. 
• Public trust & comms: misinterpretation of tiles; media narratives outrun method 
notes. 
Register fields (minimum): risk description; class; likelihood/impact; trigger 
threshold; owner; actions; due date; status; residual risk. 
Trigger thresholds (illustrative): 
• Safety: restrictive minutes/1,000 hours ↑ 20% quarter-on-quarter or review 
compliance <85% → sentinel escalation + DSC referral. 
• Integrity: e-receipt coverage <70% (pilot) or <85% (scale); exceptions ageing >10 
business days >10% of queue → rung escalation. 
• Privacy: any S1/S2 incident → immediate incident protocol; publication paused for 
affected tiles until method notes updated. 
• Workforce: OSCE pass <75% first-sit or renewal on-time <80% → examiner 
calibration + micro-hub support + scholarship release. 
Owners table risk status at each gate review; high risks appear in quarterly public 
release notes in de-identified form. 
Red-team and rehearsal program 
• Quarterly drills: fraud ring; data privacy breach; provider failure & mass switching; 
restraint-spike with media interest; interpreter failure during sentinel review. 
• Method: plan → simulate → observe → publish method notes and corrective actions; 
close within 90 days. 

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• Accountability: Program Owner tracks close-out; unresolved actions escalate to 
ministers/central agencies in the “state of the standards” brief. 
[See Implementation Roadmap (Switch-On Order); Data, Dashboards and Privacy; 
Safety & Restrictive Practices Standard.] 
Stress-Tests & Counter-Capture 
Counter-capture safeguards 
• Separation of duties: DSC and Data/Privacy independent from service delivery 
owners. 
• Cooling-off periods: no assessor of a provider they worked for in the last 24 months. 
• Publication pressure: pause rules + method notes protect against premature naming; 
reasons published, not spin. 
Stress-tests (beyond red-team drills) 
• Media surge: simulate high-profile incident; test comms + suppression; maintain 
publication cadence. 
• Political pressure: test gate integrity when expedited decisions are requested; log 
rationale. 
• Market concentration: test sanctions scenarios involving dominant providers; ensure 
continuity with rapid switching. 
Metrics 
• Tests completed; actions closed ≤90 days; independence breaches (target: zero). 
Whistleblowing and protections 
• Channels: confidential reporting to DSC Unit and Data & Privacy Office (separate to 
provider line management), plus external hotline. 
• Protections: anti-retaliation clause in contracts; sanctions for interference; right to an 
independent advocate. 
• Feedback: reporters receive acknowledgement within 5 business days and outcome 
notices when safe to do so. 
Issue management (from detection to verified closure) 
• Intake: issue logged with evidence (receipt IDs, timekeeping entries, observation 
notes). 
• Triage: classify (safety/integrity/privacy/etc.), assign owner, set SLA. 
• Root-cause: use standard templates (e.g., 5-Whys, timelines, contributory factors). 
• Actions: corrective (immediate) and preventive (systemic) with owners and due 
dates. 
• Verification: DSC/file-vs-field checks for contested or high-risk issues; Data & 
Privacy verifies data fixes. 
• Closure: owner sign-off; Program Owner confirms for material issues; dashboards 
updated; learning published. 

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Audit and evaluation interfaces 
• Internal audits: quarterly checks on sanctions consistency, switching timeliness, and 
data lineage (capture→tile). 
• External audits: annual privacy/security and method audits; findings and 
management responses published. 
• Independent evaluation: linked to Implementation Roadmap; evaluator has read-
only access to de-identified datasets and method notes. 
[See Evaluation & Continuous Learning.] 
Procurement levers and market shaping 
• Contract terms: embed standards, data duties, sanctions ladder, switching protocol, 
interpreter/AAC access, rural parity obligations. 
• Quality signals: publication feeds procurement scoring; compliant providers gain 
preference/renewal credit. 
• Remedies: corrective plans, probation, suspension and exit align with sanctions 
ladder; claw-backs apply only on verified integrity breaches (not good-faith error 
fixed promptly). 
Industrial Relations & Insurance Brief 
Workforce settings (IDC) 
• Classification & pay: align IDC grades (Foundation/Proficient/Advanced) with 
award/Bargaining bands; recognise supervision and community travel as paid time. 
• Safe workloads: maximum caseload guidance; predictable supervision ratios; time 
for 72-hour reviews and fade-planning. 
• Training time: protected hours for OSCE prep and renewal; rural 
scholarships/backfill acknowledged as work. 
Insurance & liability 
• Coverage: confirm professional indemnity for IDC practice; public liability for 
community sessions; vicarious liability covered in contracts. 
• Incidents: notify insurer when sentinel events occur; maintain artefacts (timekeeping, 
reviews) as part of the defence file. 
• Motor/transport: provider fleet or mileage policies; lone-worker check-ins for rural 
travel. 
Interfaces & compliance 
• Contracts must reflect IDC role scope; sanctions ladder and switching rules must not 
violate industrial instruments; dispute pathways documented. 
Metrics and indicators (governance dashboard) 
• Assurance cadence: % of planned audits/drills completed; gate reviews on time. 
• Risk posture: open high risks; days open; trend; actions overdue. 
• Sanctions: distribution by rung; time on rung; recurrence within 12 months. 

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• Whistleblowing: reports received; time-to-first response; substantiation rate; 
retaliation cases (target: zero). 
• Publication: on-time release rate; correction/addendum count; suppression accuracy. 
• Equity governance: MOUs active; interpreter/Auslan availability vs demand; micro-
hub uptime. 
Public tiles show de-identified governance indicators with method notes; family view 
is not used for governance metrics. 
Interfaces with other standards 
• Safety: escalation on restraint spikes; DSC involvement; learning folded into fade 
plans. 
• Truth-by-Design: exception SLAs; sanctions ladder; publication rules. 
• Independent Verification: case triggers; publication of reasons; calibration and 
double-rating results. 
• Data & Privacy: DPIAs, incident response, suppression rules, red-team drills. 
• Workforce (IDC): de-rostering rules; renewal compliance; examiner calibration. 
• Equity: MOUs, interpreter access, rural parity maintained during sanctions or 
provider exit. 
Risks and mitigations (summary) 
• Fragmented ownership: publish owner matrix; RACI is visible and current; gate 
reviews enforce clarity. 
• Perverse incentives: triangulate metrics; DSC verification; publish method notes; 
protect candour. 
• Over-centralisation: micro-hubs and local MOUs protect regional autonomy; clear 
delegation limits. 
• Publication backlash: proactive comms with Plain English/Easy Read summaries; 
contextual notes on tiles; right-of-reply included. 
• Capacity shortfalls: scholarships/backfill; shared examiner pools; pooled 
interpreters; tele-OSCEs; phased targets. 
Evaluation & Continuous Learning 
 
Purpose and scope 
 
This section makes improvement routine and public. It defines peer calibration, quality 
summaries, standard refresh rules, and independent evaluation - so results are used for 
learning, not blame. It applies across all program areas and providers. 
[See Governance, Assurance and Risk; Data, Dashboards and Privacy; Implementation 
Roadmap (Switch-On Order).] 
Principles 
• Evidence into action. Every indicator and review feeds a visible improvement step. 
• Double-loop learning. We improve both frontline practice and the standards/tools 
themselves. 

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• Transparency. Publish plain-language quality summaries with method notes and 
change logs. 
• Proportionality. Focus effort where risk and impact are highest. 
• Equity. Calibration and evaluation include rural/remote, First Nations, CALD/Auslan 
and AAC contexts. 
Peer calibration (how we align judgement) 
• Cadence: quarterly, per region. 
• Sample: stratified by risk (e.g., sentinel events, sanctions ≥ rung 3, contested 
decisions), plus a random sample of clean cases. 
• Method: 
o Blind double-rating of a minimum 10% sample (two raters score the same case 
independently). 
o Use standard rubrics (IDC observation, 72-hour review quality, e-receipt 
candour, Reasons & Weighting structure). 
o Reconcile variance; publish calibration statistics (agreement %, inter-rater 
reliability). 
o Use the EPAs mapped in Appendix AO when double-rating IDC observations. 
• Outputs: thematic findings, exemplar artefacts (de-identified), targeted micro-
modules, and OSCE/mini-OSCE station updates. 
[See Workforce Standard  -  IDC; Safety & Restrictive Practices Standard; Truth-by-
Design Standard; Independent Verification Standard.] 
Quality summaries (what we publish each quarter) 
• What’s inside: indicator movements, calibration results, improvement actions with 
owners/dates, red-team outcomes, privacy/ethics notes, and “what families can expect 
next quarter” in Plain English/Easy Read. 
• Format: 4-6 pages; charts with short legends; large-type Easy Read insert; 
translations where relevant. 
• Access: public site + provider intranet; family view links to person-level context 
when appropriate (e.g., how a change affects displays). 
• Change log: version number, what changed and why, any known limitations. 
Standard refresh and sunset rules 
• Annual refresh window: once per year per standard (Workforce, Safety, Truth-by-
Design, Independent Verification, Service Model, Equity, Data/Privacy). 
• Trigger outside window: urgent safety/privacy defect or legal change (with method 
notes). 
• Sunset test: any appendix template not used or superseded for 12 months is retired; 
keep link to its replacement. 
• Rationale note: every change has a one-paragraph “why” tied to evidence (dashboard 
trends, DSC findings, evaluation). 
Independent evaluation (external review) 
• Design: quasi-experimental (difference-in-differences) where matched controls exist; 
otherwise interrupted time series with sensitivity ranges. 

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• Pre-analysis plan: registered before data lock; publishes outcomes, subgroups 
(rural/metro, First Nations, interpreter use), and robustness checks. 
• Access: evaluator receives de-identified datasets, method notes, and read-only tile 
lineage (capture→transform→publish). 
• Timeline: interim at 12 months; full report at 24 months with public response plan. 
• Protection: evaluation independence is contractually protected; right-to-publish 
clauses with privacy safeguards. 
[See Finance & ROI Case; Data, Dashboards and Privacy.] 
Research & Evaluation Partnerships 
Partnership model 
• MoU with universities/independent institutes; pre-analysis plans; independence and 
right-to-publish clauses. 
• Data access: de-identified extracts; lineage and method notes; no raw person 
identifiers in research workspaces. 
Ethics & consent 
• Ethics approvals required; culturally safe consent processes; interpreter/Auslan/AAC 
support. 
• Do-no-harm: participants can withdraw; family view never used as a research 
workspace. 
Co-production 
• Lived-experience contributors paid; First Nations partners hold decision rights on 
topics involving their communities. 
Outputs 
• Annual research summary; repository of instruments; translation of findings into 
OSCE stations/templates and method notes. 
Continuous curriculum and tool updates 
• IDC curriculum/OSCE: updated from peer calibration themes, DSC variance, and 
red-team findings; publish a “what changed” list for candidates and examiners. 
• Safety artefacts: revise 72-hour review prompts and fade-plan templates when 
evidence shows missed steps. 
• Truth-by-Design: tune exception thresholds; add or retire codes; update UI text for 
accessibility based on family feedback. 
• Verification tools: update Reasons & Weighting exemplars and Contradiction Matrix 
hints where common logic gaps appear. 
Operational Aids  -  Consistency Prompts 
Purpose 

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Provide short, repeatable prompts that make documentation clear and consistent without 
adding paperwork. 
Prompt sets (where used) 
• IDC session notes: “Where were we? What role did we practise? What step changed? 
What’s next?” 
• 72-hour review: “Alternatives tried? Why they failed? What new alternative next? 
Who owns it? By when?” 
• E-receipt talk-through: “What was done? Did it help the goal? Do you agree to the 
receipt? Anything to add?” 
• DSC drafting: “What matched? What didn’t? Which evidence has highest weight? 
What action now?” 
(Full prompt text and Easy Read variants in Appendix AK.) 
Red-team and rehearsal integration 
• Quarterly drills (fraud ring, data breach, provider failure & mass switching, restraint 
spike, interpreter failure) feed a short “lessons learned” annex. 
• Close-out rule: all red-team actions have an owner and due date; closure is verified 
and shown on governance tiles. 
[See Governance, Assurance and Risk; Implementation Roadmap (Switch-On 
Order).] 
Roles and responsibilities 
• Program Owner (Accountable): signs off quality summaries, refresh decisions and 
evaluation scope. 
• Standard Owners (Responsible): run calibration in their domain; maintain rubrics; 
drive improvements. 
• DSC Unit (Independent): supplies variance themes; validates logic in quality 
summaries; contributes exemplar reasoning. 
• Data & Privacy Office (Independent): verifies data lineage, suppression, and 
method notes; co-authors the change log. 
• Equity Lead (Responsible): ensures calibration/evaluation include First Nations 
partnership, interpreters/Auslan/AAC, and rural parity tests. 
• Providers & Micro-hubs (Responsible): participate in calibration; implement 
improvements; evidence closure. 
• Families/Authorised representatives (Consulted): contribute to lessons learned; co-
design Easy Read elements. 
Where to get help / Artefacts & Templates (appendices index) 
• Peer calibration rubric (IDC observation; review quality; receipt candour; R&W 
structure). 
• Quality summary template (Plain English + Easy Read insert). 
• Standard refresh form (problem → evidence → change → impact). 
• Red-team scenario scripts and report template. 
• Evaluation access protocol (dataset inventory, privacy conditions). 
Templates live in Appendices (indexed); this section is the authority for content. 

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Metrics and indicators (learning dashboard) 
• Calibration: % double-rated; inter-rater reliability; variance closed within 60 days. 
• Improvements: actions raised/closed; days to close; repeat-issue rate within 90/180 
days. 
• Refresh cadence: changes delivered on schedule; number of urgent out-of-cycle 
patches (target: low). 
• Red-team: drills completed; actions open/closed; time to close. 
• Evaluation: data deliveries on time; pre-analysis plan published; report publication 
on schedule. 
• Equity: proportion of calibrated cases including interpreters/Auslan/AAC or First 
Nations partnership; rural vs metro balance. 
Implementation (switch-on order) 
• 0-3 months: publish calibration rubrics; run first quarter sample; release quality 
summary v1; register evaluation pre-analysis plan; load learning tiles. 
• 3-6 months: introduce double-rating; publish first exemplar packs; update one OSCE 
station and one review template based on findings; run at least one red-team drill. 
• 6-12 months: full quarterly cadence; independent audit of data lineage; publish first 
evaluation interim with response plan. 
• 12-24 months: annual refresh across all standards; external evaluation final; integrate 
recommendations; retire unused templates per sunset rule. 
Risks and mitigations 
• Blame culture blocking candour: protect peer review from sanctions; celebrate 
truthful correction; separate improvement logs from punitive processes. 
• Sampling bias (only “easy” cases): enforce risk-weighted sampling; publish 
sampling frame. 
• Method drift: Data & Privacy co-signs quality summaries; maintain a public method 
register with versioning. 
• Token publication: require action owners/dates in every summary; governance tiles 
track overdue items. 
• Equity blind spots: stratify all findings; set minimum rural/First Nations/interpreter 
sample shares. 
 
 
 
 
 
 
 
 

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Appendices (indexed) 
The appendices provide ready-to-use templates, schemas, checklists and concise practice 
packs that turn the standards into day-to-day actions. They are companions, not substitutes: 
definitions, thresholds and authorisations remain in the standards. Where time limits or tests 
appear here, they are developed from the standards. Use them for training, supervision, audit, 
and to file completed artefacts in the person’s record. 
 
Appendix A  -  Restraint Hierarchy & Timekeeping Standard 
Owner: Safety 
Interfaces: Safety & Restrictive Practices Standard; 72-Hour Learning Review; Fade Plan; 
Incident Reporting; Handover & Medication Reconciliation; Workforce (IDC OSCEs). 
Why this matters (and why it hasn’t worked) 
Too often restraint or rushed sedation is used because prevention skills are thin, 
authorisations are unclear, and timekeeping is patchy or done after the fact. This standard 
makes restraint emergency-only, requires start/stop timing, and forces a 72-hour learning 
review so teams replace restraint with better supports and track real change. 
Fast take (read this first) 
• Least-restrictive by default. Restraint is a last resort to prevent imminent harm only. 
• Start the clock the instant restraint begins; stop the moment it ends. 
• Record who, why, where, what type, alternatives tried, injury check, and authoriser. 
• If used, you must schedule a 72-hour learning review and update the fade plan. 
• Emergency override allowed only when prior authorisation isn’t possible and harm is 
imminent; log and notify. 
• Chemical restraint ≠ routine PRN. Any medicine primarily to control behaviour 
triggers this standard. 
• Environmental restrictions (locks, seclusion) follow the same timing and review rules. 
• Family/representative is informed unless it creates risk; note rationale either way. 
• Skills are observed (OSCEs), not assumed. Unskilled staff do not apply restraint. 
• Data feeds supervision and public reporting tiles (minutes, reviews done, injuries). 
Scope 
Applies to all services and settings covered by this White Paper (home, community, transport, 
day programs, short-stay, health interfaces incl. ED). Covers physical, mechanical, 
chemical, environmental restraints and any seclusion-like practice. 
Prohibitions (never permitted) 
• Pain-based holds; prone or prolonged supine restraint; obstructing breathing or 
communication; restraint as punishment, convenience, or routine. 
• Blanket, standing or indefinite authorisations. 

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• Restraint without continuous observation and active fade planning. 
Authorisation levels 
• Green (Prevent): proactive supports only (de-escalation, AAC, sensory/space 
changes). No restraint. 
• Amber (Planned): time-limited restraint with prior, named authorisation; competent 
staff only; person-specific plan; real-time timing and logging. 
• Red (Emergency override): imminent harm, no time for prior authorisation. Shortest 
possible duration; call for qualified lead; log immediately; notify and book review. 
Timekeeping fields (must capture) 
Person ID; date/time start-stop and total minutes; location; precipitating risk; type of restraint; 
alternatives attempted; authoriser (name/role, time of decision); staff involved (IDs); 
injuries/first aid; medication given (dose/route/indication); family/rep informed 
(time/method/rationale if not); incident category; 72-hour review booked (date/time, 
attendees); fade-plan status/updates; handover/med-recon if ED or pharmacy involved. 
How it works (step-by-step) 
1. Prevent & prepare: use green alternatives; ensure AAC and space changes are 
ready; know the person’s triggers and supports. 
2. If imminent harm: apply the least-restrictive option; start timing immediately; call 
the competent lead. 
3. During: monitor airway, circulation, distress, and communication; keep duration as 
short as possible. 
4. End & check: stop timing on release; check for injury; offer reassurance and space. 
5. Log & notify (within 2 hours): complete the timekeeping fields; notify 
manager/clinician and family/rep (or record why not). 
6. Within 24 hours: confirm authorisation trail, update the incident record, and perform 
medication reconciliation if any sedatives were given. 
7. Within 72 hours: hold the learning review; update the fade plan; schedule skill 
coaching if prevention failed; file the debrief notes. 
What good looks like / Red flags 
Good: short duration; clear “why now”; alternatives tried; competent lead present; clean logs; 
family informed; review booked and completed; fade plan tightened; injuries rare. 
 
Red flags: repeated long events; missing start/stop times; chemical restraint labelled “PRN” 
without indication; copy-paste notes; no family contact; no change after reviews. 
Who does what 
• Person/Representative: says what works; consents to planned elements where 
applicable; attends review. 
• IDC Lead (on shift): decides least-restrictive action, ensures timing/observation, 
completes log, triggers notifications. 

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• Manager/Clinician: checks authorisation trail, chairs 72-hour review, signs off on 
fade-plan changes, assigns coaching. 
• Provider Director/Safety: runs audits, trend analysis, and publishes tiles; escalates 
sentinel patterns. 
• External (DSC/OPA/Tribunal/Health): verifies logs vs field, resolves disputes, 
ensures lawful thresholds. 
Emergency override (exact steps) 
1. Confirm imminent harm and no safer alternative. 
2. Apply least-restrictive option; start timer. 
3. Call competent lead; maintain observation and airway. 
4. End ASAP; stop timer; first-aid check. 
5. Complete log and notifications; book 72-hour review. 
Debrief prompts (use at review) 
• What happened before “the moment”? (triggers, environment, communication) 
• What helped/hurt? (supports used, words, people present) 
• What changes now? (routine, environment, skills, community plan) 
• What will we try first next time? (named alternatives, role assignment) 
• How do we measure drift or improvement? (minutes, frequency, injury rate) 
Micro-scenarios 
• Community escalation: Loud venue + sensory overload → staff use AAC yes/no and 
step-out plan; risk escalates; 40-second hold to prevent running into traffic; timer 
started/stopped; log done; family informed; review in 72 hours refines “early exit” cue 
and transport plan. 
• ED presentation: Agitation, pain unknown → interpreter/AAC used; single-dose 
short-acting sedative given for procedure safety (logged as chemical restraint); med-
recon completed; review sets a “pain-first” protocol and flags allergy assessment. 
Quick scripts 
• Explaining least-restrictive: “We only use restraint if someone is in immediate 
danger. We try other options first and, if we must use it, we time it and stop as soon as 
it’s safe.” 
• Informing family/rep: “There was a brief restraint today to prevent harm. It lasted 
[minutes]. We’ve booked a review within 72 hours to improve the plan.” 
Where to get help / Artefacts & Templates 
• Templates: Restrictive Practice Log; 72-Hour Learning Review; Fade Plan; Incident 
Report; Medication Reconciliation. 
• See also: 72-Hour Learning Review; Fade Plan; Handover & Medication 
Reconciliation; Reasons & Weighting / Contradiction Matrix. 
Summary companion. Decisions rely on the governing sections in “Safety & Restrictive 
Practices Standard”. 

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Appendix B  -  72-Hour Learning Review Template 
Owner: Safety & Quality 
Interfaces: Restraint Hierarchy & Timekeeping; Fade Plan; Incident Reporting; Handover & 
Medication Reconciliation; Workforce (IDC OSCEs); Data & Dashboards; Governance & 
Complaints. 
Why this matters (and why it hasn’t worked) 
After serious incidents, teams often “move on” without extracting the lessons that prevent 
repeats. Reviews are delayed, defensive, or focused on paperwork rather than change. This 
template makes learning timely (within 72 hours), person-centred, and action-oriented, so 
supports improve and restraint becomes rarer, shorter, and safer. 
Fast take (read this first) 
• Hold the review within 72 hours of any restraint/seclusion-like event, serious 
medication error, or sentinel risk. 
• Attendance: IDC lead on shift, line manager/clinician, the person and/or 
representative (with supports), any relevant specialist; independent chair when 
contested. 
• Inputs ready: timekeeping log, incident notes, medication reconciliation, relevant e-
receipt/roster records, CCTV or witness statements (if available). 
• Meeting flow: facts → why now → what helped/hurt → what changes → who does 
what by when. 
• Outputs: updated Fade Plan, specific actions with owners and due dates, coaching 
assignments, and dashboard flags. 
• Tone: learning not blame. Improvement logs are separate from sanctions processes. 
• Accessibility: interpreters/AAC provided; plain-language summary offered to the 
person/family. 
• Measurement: track minutes, frequency, injuries, and action close-outs at 30/60/90 
days. 
Triggers (when a 72-hour review is mandatory) 
• Any use of physical, mechanical, chemical, or environmental restraint (including 
seclusion-like practices). 
• Serious medication error or emergency sedation related to behavioural distress. 
• Injury to the person or staff during an escalation. 
• Repeated near-misses showing drift in prevention supports. 
Who attends (and roles) 
• Chair (manager or independent lead): keeps time, ensures psychological safety, 
decides action owners. 
• IDC lead on shift: presents facts and alternatives attempted; confirms timekeeping 
accuracy. 
• Person/Representative: describes experience, preferences, early warning signs, and 
what “good help” looks like. 

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• Clinician/Specialist (as relevant): contributes to differential causes (pain, infection, 
communication barriers). 
• Recorder: completes the one-page summary and action register live. 
• Observer/Coach (optional): notes practice gaps and schedules coaching. 
Inputs to bring (minimum pack) 
• Restrictive Practice Log (start/stop times; alternatives; authorisation). 
• Incident report; injury check; photos (if relevant). 
• Medication reconciliation (if sedatives given). 
• E-receipt exceptions and any roster↔claim mismatches for the period in question. 
• Any environmental or staffing notes (staffing levels, room layout, noise triggers). 
• Person’s profile/communication plan and current Fade Plan. 
How the review runs (step-by-step) 
1. Schedule & invite (within 24 hours): set the meeting for Day 1-3; confirm 
interpreter/AAC; send pre-read pack. 
2. Open (5 minutes): purpose, rules (learning focus, respect, timebox), introduction of 
attendees; confirm the person’s preferences for participation. 
3. Facts on the table (10 minutes): what happened, when, where; the exact start/stop 
times; alternatives tried; authorisation steps. 
4. Why now? (15 minutes): immediate triggers, unmet communication needs, 
pain/health checks, environment, staffing, routines, known patterns. 
5. What helped/hurt? (10 minutes): strategies that reduced or escalated distress; 
words, people, places. 
6. Decisions (15 minutes): update Fade Plan; add early-exit cues; adjust 
routines/environment; order health checks; assign coaching; confirm measures. 
7. Record & close (5 minutes): action owners/dates; follow-up meeting if high-risk; 
share plain-language summary. 
Outputs (file and act on these) 
• One-page summary (plain English) capturing facts, causes, decisions, and due dates. 
• Action register with owners, deadlines, and check-backs (30/60/90 days). 
• Updated Fade Plan and communication supports (yes/no boards, scripts, sensory 
plan). 
• Coaching plan (who, what skill, by when) and OSCE booking if competence needs 
re-assessment. 
• Data updates to dashboards: total minutes, number of events, injuries, reviews on 
time, actions closed. 
What good looks like / Red flags 
Good: review held on time; person voice present; specific changes to supports and 
environment; actions closed by due date; subsequent events are shorter/rarer; notes are clear 
and non-defensive. 
Red flags: meeting delayed or cancelled; vague “staff to be more vigilant” actions; no update 
to Fade Plan; repeated long events with identical notes; missing start/stop times. 

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Debrief prompts (use in the room) 
• What were the first signs things were going off-track? 
• What words or supports worked best in the moment? 
• What system factor (roster, environment, access, training) made it harder? 
• What one change will we trial first - and how will we know if it works in 14 days? 
• What could have prevented this earlier in the day/week? 
Micro-scenarios 
• Community setting: Escalation at a noisy venue; brief physical hold to prevent 
running onto a road; review adds a “quiet exit” cue, pre-visit sensory check, and 
transport backup. 
• ED interface: Agitation with undiagnosed pain; single-dose short-acting sedative 
used; review adds “pain-first” protocol, GP follow-up, and an alert on allergies/side-
effects. 
Quick scripts 
• Invite to family/rep: “We’re holding a learning review within 72 hours to reduce the 
chance of this happening again. We’ll use plain language, and you can bring supports 
or ask for an interpreter.” 
• Open the meeting: “This is about learning, not blame. We’ll look at what happened, 
why now, and what we change today.” 
Storage, privacy & follow-through 
• File the one-page summary, action register, and updated Fade Plan in the person’s 
record. 
• Keep improvement records separate from any sanctions investigation. 
• Share the plain-language summary with the person/representative (unless doing so 
creates risk - record the rationale). 
• Add the “review on time” and “actions closed” ticks to dashboards. 
Where to get help / Artefacts & Templates 
• 72-Hour Learning Review  -  One-Page Summary 
• Action Register (with 30/60/90-day check-backs) 
• Debrief Prompts sheet (room copy) 
• Chair’s Checklist (before/during/after) 
• Plain-Language Summary handout 
 
Summary companion. Decisions rely on the governing sections named in the Safety & 
Restrictive Practices Standard and related policies. 

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Appendix C  -  Fade Plan Template (Restraint-Reduction & Positive 
Supports)  
Owner: Safety & Practice 
Interfaces: Restraint Hierarchy & Timekeeping; 72-Hour Learning Review; Communication 
Access; Health & Medication Reconciliation; Workforce (IDC OSCEs); Data & Dashboards. 
Why this matters (and why it hasn’t worked) 
Restraint use often repeats because teams don’t convert lessons into a clear, shared plan with 
early cues, ready alternatives and accountable follow-through. Generic “be vigilant” notes 
change nothing. A Fade Plan makes restraint rarer, shorter and safer by setting concrete 
targets, ordering better options, and assigning owners with dates. 
Fast take (read this first) 
• Purpose: replace restraint with effective supports; shorten any event that still occurs. 
• Always include: early warning cues, what to try in order, who does what, time-
bound goals, and how progress is measured. 
• Keep it live: update after every 72-hour learning review or sentinel change. 
• Guardrails: no blanket time-based fades; no punitive language; chemical restraint is 
never a “strategy”. 
• Success looks like: fewer events, shorter minutes, fewer injuries, better participation. 
Triggers (when to create/update) 
• New service start or setting change (home → day program → ED). 
• After any restraint/seclusion-like event or emergency sedation. 
• When patterns shift (new health issue, medication change, environment, staffing). 
• When goals advance (e.g., expanding community roles). 
Who’s in the room (and roles) 
• Person/Representative (supported): preferences, triggers, what helps. 
• IDC Lead: coordinates drafting; ensures practical steps. 
• Clinician/Specialist (as relevant): communication, sensory, medical input. 
• Family/Key Allies: context, community opportunities. 
• Recorder: completes the one-page summary during the meeting. 
• Coach/Trainer (optional): converts plan into shifts and OSCE practice. 
Inputs you must have 
• Most recent 72-Hour Learning Review summary and actions. 
• Restrictive Practice Log (start/stop times; alternatives tried). 
• Communication profile/AAC tools and scripts. 
• Health updates (pain, infection risk, meds, side-effects). 
• Environment map (noise, space, transport, seating, exits). 
• Roster capacity (who’s competent; who needs coaching). 

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Template  example  -  One-Page Fade Plan (complete live) 
 
A. Person summary (2-3 lines) 
Strengths, interests, key values, primary communication modes. 
B. Early warning cues (ranked)  -  “First signs” 
1. … 2) … 3) … 
C. What to try first (green supports)  -  in order 
1. Words that work (exact phrases): … 
2. Communication supports (yes/no, pictures, device): … 
3. Environment changes (quiet space, lighting, step-out): … 
4. Activity/routine adjustments (breaks, sequencing): … 
5. Sensory supports (pressure, movement, headphones): … 
D. If risk escalates (amber responses)  -  time-limited 
• Team roles (who leads, who clears space): … 
• Safe positioning/space management: … 
• Call criteria for clinical/backup: … 
E. Only if imminent harm (red, emergency-only) 
• Least-restrictive option; start/stop timing; notify. 
• Post-event: injury check; family/rep contact; log; 72-hour review. 
F. Health checks & medication notes 
Pain first? GI/UTI flags? Allergy/side-effect watch-outs. PRN rules (if any): indication, dose, who 
authorises (never for convenience). 
G. Participation & daily rhythm anchors 
Weekly community roles, times, allies, and transport plan. 
H. Goals & measures (90-day horizon) 
• Reduce total restraint minutes by: ___% (baseline: ___ mins/month). 
• Max event length: ___ minutes (from ___). 
• Zero injuries for ___ days. 
• Participation: ___ outings/week; ___ named roles. 
• Coaching: ___ staff complete OSCE ___ by ___/____. 
I. Actions & owners 
Action | Owner | Due | Check (30/60/90d) 
 - | - | - | -  

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J. Reviews & sign-off 
Next review date: ___/____ (or after any event). 
Person/Rep: ___ IDC Lead: ___ Clinician (if any): ___ Manager: ___ 
 
 
How to build the plan (30-40 minutes) 
1. Open with voice and values (5 min): person/rep states what matters; confirm 
supports (interpreter/AAC). 
2. List early cues (5 min): capture first signs seen by family/frontline; make them 
observable. 
3. Order green supports (10 min): write exact phrases and actions; sequence them. 
4. Define amber roles (5 min): who leads; how the room changes; when to call help. 
5. Set health checks (5 min): rule out pain/infection; confirm med notes. 
6. Set goals & actions (10 min): measurable targets; owners and dates; book 
coaching/OSCEs. 
What good looks like / Red flags 
Good: short, lived plan; exact words; clear sequence; owners named; measures tracked; plan 
updated after reviews; participation grows. 
Red flags: vague “de-escalate” lines; no sequence; punitive tone; PRN as behaviour control; 
no person voice; plan not used in shift huddles. 
Micro-scenarios (worked) 
• Shopping centre (noise surge): Early cue = head-clutching → Step 1 phrase: “Quiet 
exit?” + point to card → Step-out route to car → Five-minute reset with music → 
Return via side entrance or reschedule. 
• Day program (crowded room): Early cue = pacing → Offer headphones + outdoor 
lap → Swap task to preferred role → If escalates, clear space and rotate staff lead → 
Emergency-only hold if running risk; time and log. 
Quick scripts 
• Explaining the plan to the person/rep: “This plan lists the first signs things feel 
wrong, the words and supports that help most, and who does what. If danger is 
immediate, we use the safest option briefly and time it. We review every event to 
keep improving.” 
• Shift huddle opener (60 seconds): “Today’s cues: ___; first supports: ___ → ___ → 
___. If it climbs: ___ leads, ___ clears space. Health watch: ___. Goal this week: 
___.” 
Storage, privacy & use in practice 
• Keep the one-pager at point-of-care and in the person’s record; update after each 
review. 
• Bring the plan to shift huddles and supervision. 

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• Share with the person/rep in plain English/Easy Read unless that creates risk (record 
rationale). 
• Feed measures to dashboards (minutes, frequency, injuries, participation, coaching 
completion). 
Where to get help / Artefacts & Templates 
• Fade Plan  -  One-Page Template (fields A-J) 
• Shift Huddle Card (cues → green supports → roles) 
• Action Register (with 30/60/90-day checks) 
• OSCE Coaching Map (which skills, who, when) 
 
Summary companion. Decisions rely on the governing sections named in the Safety & 
Restrictive Practices Standard and related policies. 
 
Appendix D  -  Handover & Medication Reconciliation Pack 
Owner: Health & Safety 
Interfaces: Safety & Restrictive Practices; Restraint Hierarchy & Timekeeping; 72-Hour 
Learning Review; Fade Plan; Workforce (IDC); Data & Dashboards; Privacy (DPIA); 
Pharmacy Stewardship. 
Why this matters (and why it hasn’t worked) 
People bounce between home, GP, pharmacy and ED with fragmented information, so 
medicines get duplicated, stopped without reason, or added as quick fixes for distress. That 
drives avoidable ED returns and chemical restraint drift. This pack makes handover 
standard, and medication reconciliation mandatory within 72 hours, so everyone works 
from one safe, shared list and a clear plan. 
Fast take (read this first) 
• Use this pack for every transition (home↔GP↔pharmacy↔ED↔short-stay↔day 
program). 
• Bring a Health Passport: conditions, allergies, current meds 
(name/strength/route/indication), communication needs, guardian/representative 
details. 
• At handover: state the reason for presentation, what was tried already, any restraint 
minutes, and what usually works. 
• On discharge/return: you must reconcile medicines within 72 hours: current, 
changed, started, stopped - each with an indication and who authorised it. 
• Chemical restraint rules still apply: if a medicine is used primarily to control 
behaviour, log and review it. 
• Kill-switches: red-flag high-risk combos, duplicate psychotropics, or unclear PRNs; 
escalate to prescriber/pharmacist immediately. 

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• Measure it: track 72-hour reconciliation completion, avoidable ED returns (7/30 
days), and polypharmacy rates. 
Scope 
All community, primary care, pharmacy, dental, mental health and hospital interfaces 
covered by this White Paper. Applies to prescription, OTC and complementary medicines 
and to sedation given for procedures. 
 
Part 1  -  Standard handover (to ED/GP/pharmacy/dental) 
Minimum handover fields (complete or state “unknown”) 
• Reason for presentation and time of onset. 
• What was attempted (supports/strategies; any restraint minutes with start/stop). 
• Baseline health & recent changes (pain, infection flags, sleep, hydration, bowel). 
• Current medicines (name/strength/route/frequency/indication). 
• Allergies & adverse reactions (what happened, when). 
• Communication access (AAC, interpreters, yes/no methods). 
• Consent/guardian/representative details (name, phone). 
• Risk notes (seizure, choking, diabetes, anticoagulants, wandering). 
• What usually helps (exact phrases, sensory aids, step-out plans). 
Attach (if available) 
Health Passport; last 72-Hour Review summary; Fade Plan one-pager; Restrictive Practice 
Log (if relevant); recent pathology/letters; GP details; pharmacy contact. 
 
Part 2  -  Discharge/hand-back (what must come back with the person) 
• Diagnosis or working diagnosis (plain English). 
• Procedures done and sedation given (drug/dose/route/time/indication). 
• Meds started/changed/stopped with reasons and duration (e.g., “amoxicillin 500 mg 
TDS 5 days for otitis media”). 
• Monitoring required (vitals, side-effects to watch; who to call). 
• Follow-ups booked or required (GP by date, tests, referrals). 
• Red flags for return to ED. 
• Contact for the treating team. 
 
Part 3  -  Medication reconciliation (within 72 hours) 
Definition 
A structured process to verify and document a single, correct medicine list by comparing 
all sources (person/rep, GP summary, pharmacy dispense history, ED/hospital discharge, 
provider notes). 
Steps (do these in order) 

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1. Collect sources: Health Passport; discharge summary; GP summary; pharmacy list; 
carer/provider list. 
2. Build the “one list”: for each medicine, record name, strength, route, frequency, 
indication, start/stop, prescriber. 
3. Resolve conflicts: duplicates, dose mismatches, unclear PRNs; call the 
prescriber/pharmacist; document decisions. 
4. Apply red-flag rules (see below). 
5. Update the person’s record and share the list (plain English/Easy Read where 
appropriate) with the person/rep, GP and pharmacy. 
6. Set review dates (e.g., antipsychotic review in 4 weeks; antibiotic stop date). 
7. Log completion in dashboards (reconciled ≤72h: yes/no; actions raised). 
Red-flag rules (act the same day) 
• Poly-psychotropic (≥2 psychotropics without clear indications/plan) → escalate to 
prescriber and schedule review. 
• Sedation added for behaviour without pain/medical assessment → trigger Safety & 
Restrictive Practices review. 
• Duplicate drug classes (e.g., two SSRIs; two anticholinergics) → clinician check. 
• High-risk interactions (e.g., macrolide + QT-prolonging antipsychotic) → 
pharmacist review. 
• Unclear PRNs (no indication/max dose) → clarify or hold. 
 
Who does what 
• Person/Representative: brings/passports information; states what works; receives the 
final list in plain language. 
• IDC Lead (provider): completes handover, ensures the 72-hour reconciliation, files 
documents, books follow-ups. 
• GP/ED/Dental Clinician: documents changes with indications; provides clear 
discharge/hand-back. 
• Pharmacist: performs clinical check, flags interactions, supports de-prescribing 
plans, updates dispense records. 
• Manager/Clinician (provider): monitors completion rates; escalates red-flags; 
ensures coaching where gaps appear. 
 
What good looks like / Red flags 
Good: complete handover at arrival; discharge summary with clear indications; reconciliation 
finished ≤72h; updated one-list shared; reduced duplicate psychotropics; fewer ED returns. 
Red flags: person arrives with no Health Passport; vague discharge notes (“continue usual 
meds”); no reconciliation; unclear PRNs; rising sedation use; repeat ED within 7 days with 
the same issue. 
 
Micro-scenarios (worked) 

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• ED agitation with pain: Person arrives with Health Passport; staff try AAC and step-
out; short-acting sedative used for scan; discharge lists dose/time/indication; provider 
reconciles next day, adds pain-first protocol and books GP review. 
• Dental procedure: Planned graded desensitisation fails; minimal sedation used; 
pharmacy provides post-procedure advice; reconciliation confirms stop date and adds 
home oral-health routine. 
• GP antibiotic change: New macrolide added; pharmacist flags QT-risk with 
antipsychotic; prescriber switches to safer option; documented same day. 
 
Quick scripts 
• At triage: “Here’s the Health Passport and today’s reason. These are the medicines, 
allergies, and what works to calm things quickly.” 
• Calling the pharmacist/prescriber: “I’m reconciling meds after an ED visit. I’m 
seeing [drug/dose]; indication isn’t listed. Can we confirm keep/stop and the review 
date?” 
• Explaining reconciliation to family: “Within 72 hours we check every medicine 
from all sources and agree on one correct list. You’ll get a plain-language copy.” 
 
Privacy, storage & data 
• File the handover sheet, discharge summary and reconciled list in the person’s record; 
share only with those who need to know. 
• If devices or photos are used to capture lists, follow the DPIA and delete transient 
images after filing. 
• Dashboards track: reconciled ≤72h (%), avoidable ED returns (7/30 days), poly-
psychotropic rate, PRN clarifications raised/closed. 
 
Where to get help / Artefacts & Templates 
• Standard Handover Sheet (all settings) 
• ED Arrival Handover + ED Discharge Summary (plain-English companion) 
• GP Hand-Back Form (changes, indications, review dates) 
• Medication Reconciliation Checklist (72-hour) 
• Health Passport (conditions, allergies, contacts, communication) 
• Allergy & Adverse Reaction Card (wallet-size) 
 
Summary companion. Decisions rely on the governing sections named in the Safety & 
Restrictive Practices Standard, Health Interface policies and Privacy/DPIA. 
 

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Appendix E  -  Minimum Two-Party E-Receipt JSON Schema (v1.x) 
Owner: Integrity & Data 
Interfaces: Truth-by-Design Standard; Roster↔Claim Cross-Checks; Dashboards 
(public/family/provider); Complaints & Sanctions Ladder; Privacy/DPIA; Accessibility 
(AAC/translation). 
Why this matters (and why it hasn’t worked) 
Narrative notes and after-the-fact invoicing can hide mismatches between what was rostered, 
what happened, and what was claimed. People and families rarely see or can confirm the 
details. A two-party e-receipt makes the truth observable: one compact record that both 
sides can view and attest to, with enough structure to audit and enough accessibility to use in 
real life. 
Fast take (read this first) 
• Capture a single receipt per session (or logical block). 
• Two-party means: worker submits; person/nominee/guardian can attest in accessible 
ways (tap, PIN, biometric, verbal-witnessed, alt-comm). 
• Payload uses pseudonym keys (no names), ISO timestamps and minimum fields 
only. 
• Minutes are timed, not guessed. If offline, store and auto-submit later with a 
submitted_at timestamp. 
• Attestation states: present? accurate? any exceptions (e.g., E7 = declined). 
• Feeds roster↔claim sweeps before payment and powers the family view and public 
integrity tiles. 
• Privacy by design: geolocation is fuzzed and only coarse geohash is stored; 
attachments are optional and minimal. 
Scope 
All funded supports covered by this paper across home, community, health, education, work 
and tele-supports. Applies to agency-managed, plan-managed and self-managed contexts. 
Works online and offline. 
 
Required data (JSON Schema  -  minimum) example 
This schema is deliberately small. You can extend it locally, but do not remove required 
fields. 
{ 
  "$schema": "https:___/json-schema.org/draft/2020-12/schema", 
  "title": "Disability Support E-Receipt (Minimum)", 
  "type": "object", 
  "required": [ 
    "receipt_id", 
    "person_psn", 
    "worker_psn", 
    "provider_abn", 
    "service_start", 

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    "service_minutes", 
    "activity_code", 
    "domain", 
    "location_type", 
    "consent", 
    "attest", 
    "integrity", 
    "device" 
  ], 
  "additionalProperties": true, 
  "properties": { 
    "receipt_id": { "type": "string", "description": "ULID/UUIDv7" }, 
    "person_psn": { "type": "string", "description": "Pseudonym key (no names)" }, 
    "worker_psn": { "type": "string", "description": "Pseudonym key (no names)" }, 
    "provider_abn": { "type": "string", "pattern": "^[0-9]{11}$" }, 
 
    "service_start": { "type": "string", "format": "date-time" }, 
    "service_minutes": { "type": "integer", "minimum": 5 }, 
 
    "activity_code": { "type": "string" }, 
    "domain": { "type": "string", "enum": ["home", "community", "health", "education", 
"work", "other"] }, 
    "location_type": { "type": "string", "enum": ["home", "onsite", "public", "tele"] }, 
 
    "goal_link": { "type": "string" }, 
    "notes_min": { "type": "string", "maxLength": 480 }, 
 
    "cpi_flags": { 
      "type": "object", 
      "properties": { 
        "counts_for_cpi": { "type": "boolean" }, 
        "variety_tag": { "type": "string" }, 
        "role_depth": { "type": "string", "enum": ["observer", "member", "helper", "paid"] 
} 
      } 
    }, 
 
    "consent": { 
      "type": "object", 
      "required": ["who", "mode", "timestamp"], 
      "properties": { 
        "who": { "type": "string", "enum": ["person", "nominee", "guardian", "parent"] }, 
        "mode": { "type": "string", "enum": ["tap", "pin", "biometric", "verbal-witnessed", 
"alt-comm"] }, 
        "timestamp": { "type": "string", "format": "date-time" }, 
        "witness_psn": { "type": "string" } 
      } 
    }, 
 
    "attest": { 
      "type": "object", 
      "required": ["present", "accuracy"], 
      "properties": { 
        "present": { "type": "boolean" }, 
        "accuracy": { "type": "boolean" }, 
        "exceptions": { "type": "array", "items": { "type": "string" } } 
      } 
    }, 
 
    "device": { 
      "type": "object", 
      "properties": { 
        "platform": { "type": "string" }, 
        "app_version": { "type": "string" }, 
        "offline": { "type": "boolean" }, 
        "submitted_at": { "type": "string", "format": "date-time" } 

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      } 
    }, 
 
    "integrity": { 
      "type": "object", 
      "required": ["hash", "prev_hash"], 
      "properties": { 
        "hash": { "type": "string" }, 
        "prev_hash": { "type": "string" }, 
        "sig": { "type": "string" }, 
        "device_attest": { "type": "string" } 
      } 
    }, 
 
    "geo": { 
      "type": "object", 
      "properties": { 
        "geohash_5": { "type": "string" }, 
        "fuzz_m": { "type": "integer" } 
      } 
    }, 
 
    "attachments": { "type": "array", "items": { "type": "string" } } 
  } 
} 
 
 
• person_psn / worker_psn: stable pseudonym keys; names live in secure directories, 
not in receipts. 
• service_start: ISO-8601 in UTC or local with offset. 
• service_minutes: integer, timed from actual start/stop. 
• activity_code: your local service taxonomy; map once for dashboards. 
• consent.mode: ensures accessible attestation (AAC and verbal-witnessed are valid). 
• attest.exceptions: string list for edge cases (e.g., E7 = “declined”). The full 
catalogue will live in Appendix AA; use E-codes in the payload and explain them in 
UIs. 
• integrity.hash/prev_hash: allows chained receipts and tamper-evident export. 
• geo: store coarse location only (e.g., geohash-5) plus a fuzz_m value (metres). 
• attachments: optional artefacts (e.g., a photo of an accessible signature panel). Keep 
minimal. 
 
Validation rules (minimum) 
• All required fields present and non-null. 
• ABN = 11 digits. 
• service_start and consent.timestamp are valid ISO date-times. 
• service_minutes ≥ 5. 
• domain, location_type, role_depth must match allowed values. 
• If attest.present = false or attest.accuracy = false, an exceptions entry is required 
(use E-codes; e.g., E7). 
• If device.offline = true, device.submitted_at must be set (≤ local policy window, 
e.g., 48 hours). 
• If attachments exist, file types and size follow DPIA limits. 

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Workflow (who does what) 
1. Worker ends session → generates receipt; confirms minutes, activity_code, domain, 
short note. 
2. Person/Representative reviews on-screen (Easy Read/AAC) → attests (or declines = 
E7). 
3. App stamps device info, integrity hash and coarse geo (if enabled); stores offline if 
needed. 
4. Provider system runs validators and roster↔claim cross-check. 
5. Exceptions route to a courtesy check queue; unresolved items surface to supervision 
and (if patterns emerge) sanctions review. 
6. Dashboards update: person/family view (history and corrections), provider quality 
tiles, and public integrity tiles (suppressed/small-cell protected). 
 
What good looks like / Red flags 
Good: same-day receipts; clear consent mode; accurate minutes; rare exceptions; 
roster↔claim match rates > 98%; family view used. 
 
Red flags: batch entries days later; missing consent; repeated E-codes from the same 
worker/team; rising “tele” claims without supporting context; long notes that still don’t 
explain minutes. 
 
Micro-scenarios 
• Community outing: 90 minutes at local club; person taps to attest; 
domain=community, role_depth=member; geo stored at geohash-5 with 150 m 
fuzz; shows in family view same day. 
• Low-signal farmhouse (offline): receipt saved offline; device.offline=true; 
submitted next morning with submitted_at set; passes the window; no exception. 
• Person declines (E7): worker records the work done; attest.present=true, 
accuracy=false, exceptions=["E7"]; courtesy check triggers; supervisor calls family 
to resolve. 
 
Quick scripts (frontline use) 
• Explaining the why (20 seconds): “We use a simple receipt so you can see what 
happened and agree. It protects you and us, and keeps claims honest.” 
• If someone declines: “No problem - your choice is recorded. A supervisor will follow 
up so we can fix anything not right.” 
 
Privacy, storage & retention 
• Pseudonym keys only in the payload; identities live in the provider directory. 

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• Coarse location and fuzzing by default; precise GPS never published. 
• Receipts are retained per funding rules; exports are hashed and tamper-evident. 
• Public dashboards use suppression for small cells; family view shows full history to 
the person/rep. 
 
Where to get help / Templates & artefacts 
• UI copy deck (plain-English/AAC screens for attestation) 
• Courtesy-check flow (states, SLAs, escalation) 
• Roster↔Claim cross-check rules (minimal set) 
• Exception codes list (E-series; E7 = Declined)  -  maintained in Appendix AA 
• Family view explainer (what appears, how corrections show) 
 
Summary companion. Decisions rely on the governing sections named in the Truth-by-
Design Standard, Privacy/DPIA and associated integrity policies. 
 
Appendix F  -  Roster-to-Claim Cross-Check Rules 
Owner: Truth-by-Design 
Interfaces: E-Receipt Schema; Dashboards & Suppression; Governance & Complaints; 
Sanctions Ladder; Privacy/DPIA; Finance. 
Why this matters (and why it hasn’t worked) 
Traditional invoicing and narrative notes don’t reliably show what was rostered, what 
actually happened, and what was claimed. This creates padding risk, erodes trust, and 
leaves the person/family out of the loop. Cross-checks make the truth observable before 
payment: every claim is matched to a rostered session and an e-receipt, with clear rules for 
variances and a timed path to resolve exceptions. 
Fast take (read this first) 
• Run the cross-check before any claim is paid. 
• Each claim must match (a) a roster record and (b) a two-party e-receipt (Appendix 
E). 
• The engine checks: existence, timing window, minutes variance, worker role/scope, 
location/domain, overlaps/duplicates, and attestation state. 
• Items that fail drop into an exceptions queue with clear E-codes (E1-E8) and SLA 
tiers. 
• Family view shows history and corrections; public tiles show match-rates (suppressed 
for small cells). 
• Privacy by design: pseudonym keys only; coarse location; audit-logged decisions. 
Scope 

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All paid supports under this paper, across home, community and tele-supports, including 
travel where applicable. 
 
The rules (pass/fail logic) example 
Threshold values marked [POLICY] are set in the Standards and may be tightened over time. 
1. Existence 
o Roster record exists for the period. 
o E-receipt exists for the same session. 
o Fail → E1 (no roster) or E2 (no receipt). 
2. Timing window 
o Receipt service_start within [POLICY: start tolerance] of roster start, and 
service_minutes within [POLICY: minutes tolerance] of rostered duration. 
o Fail → E3 (timing/minutes variance). 
3. Role & scope 
o Worker’s current role/credential allows the activity_code (e.g., safety tasks 
require assessed competence). 
o Fail → E4 (scope mismatch). 
4. Location/domain 
o Receipt domain/location_type is compatible with the rostered category 
(home/community/tele). 
o Fail → E5 (location/domain mismatch). 
5. Overlap/duplicate 
o Worker and person have no overlapping paid sessions beyond [POLICY]. 
o Duplicate receipt/claim IDs are rejected. 
o Fail → E6 (overlap/duplicate). 
6. Attestation state 
o attest.present = true and accuracy = true, or a valid exception code is 
recorded. 
o E7 is reserved for declined/contested by person/rep; routes to courtesy-check. 
7. Timeliness 
o Offline submissions must be uploaded within [POLICY: offline window]; 
claims lodged within [POLICY: claim window]. 
o Fail → E8 (late submission). 
Optional checks (if configured): geohash plausibility vs planned venue; travel adjacency; 
maximum daily hours per worker/person; hard blocks where sanctions apply. 
 
Exception codes (E-series) 
• E1: Missing roster record 
• E2: Missing e-receipt 
• E3: Time/minutes variance beyond tolerance 
• E4: Worker role/credential doesn’t permit activity 
• E5: Location/domain mismatch 
• E6: Overlap/duplicate session 
• E7: Person/rep declines or contests details 

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• E8: Late submission (offline/claim window breach) 
Full catalogue with UI copy and remediation steps is maintained in Appendix AA. 
 
SLAs and escalation (resolve before payment) 
Tier 1  -  Same day to 2 business days 
• E1/E2/E3/E5/E8 where evidence is available (fix records, correct minutes, re-attest if 
needed). 
• Owner: Supervisor/rostering lead. 
Tier 2  -  Within 5 business days 
• E4/E6 or repeated Tier-1 failures; requires manager review and credential/roster 
correction. 
• Owner: Service manager; finance hold remains. 
Tier 3  -  Governance alert (within 10 business days) 
• Unresolved E7, patterns suggesting fraud, or repeat non-compliance. 
• Owner: Governance/Integrity; may trigger sanctions process and external notification. 
Finance releases only on pass or resolved exception with audit notes. 
 
Workflow (who does what) 
1. Worker completes session → e-receipt generated and attested (or E7 recorded). 
2. System runs cross-checks on import; passes flow to payment; failures to exceptions 
queue. 
3. Supervisor works the queue by SLA tier; contacts person/rep for E7 (courtesy-
check), fixes roster data, or returns to worker for correction. 
4. Manager/Governance handle Tier-2/3, apply sanctions where required, and publish 
quality tiles. 
5. Dashboards update match-rate, exception mix, and mean time-to-resolve; family 
view shows corrections. 
 
What good looks like / Red flags 
Good: ≥ [POLICY] overall match-rate; low E-code volume; corrections made inside SLA; 
clear audit notes; families use the view; no repeat scope or overlap issues. 
Red flags: batch receipts days later; spike in E3/E6; the same worker/team generating most 
exceptions; unresolved E7s; finance overrides without audit notes. 
 
Micro-scenarios (worked) 

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• Minutes variance (E3): Roster 120 min; e-receipt 90 min. Supervisor corrects to 90, 
worker adds note; claim pays for 90. 
• Scope mismatch (E4): Worker without verified safety OSCE logs a complex 
behaviour support. Manager reallocates, books OSCE, declines claim. 
• Person declines (E7): Family contests accuracy. Courtesy-check call clarifies 30 
minutes were travel; worker adds travel code and adjusted minutes; family re-attests. 
 
Quick scripts (frontline & supervisor) 
• Explaining cross-checks: “Claims only pay when roster, receipt and minutes line up. 
It keeps things fair and transparent for everyone.” 
• Courtesy-check opener (E7): “You declined the receipt yesterday. Can we walk 
through what happened so we can correct it together?” 
 
Data, privacy & audit 
• Use pseudonym keys in cross-checks; identities live in secure directories. 
• All changes produce audit-log events (Appendix T) with who/when/what-changed. 
• Public reporting shows match-rate and exception resolution times with small-cell 
suppression; family view shows full history to the person/rep. 
 
Where to get help / Templates & artefacts 
• Rule table (with [POLICY] tolerances) 
• Exceptions queue workflow (kanban + SLAs) 
• Resolution note template (mandatory fields) 
• Courtesy-check script pack 
• Finance hold/release checklist 
 
Summary companion. Decisions rely on the governing sections named in the Truth-by-
Design Standard, Finance policy and Privacy/DPIA. 
 
Appendix G  -  Sanctions, Reasons & Weighing (R&W), Contradiction 
Matrix, and Independent-Reasoning Certificate (IRC) 
Owner: Integrity & Enforcement Lead (with Legal) 
Operational owners: DSC Panel Secretariat; Registry/OPA/NDIA stewards (per case) 
Interfaces: Two-Key Register; R&W Store (Appendix H); Contradiction Matrix (Appendix 
I); IRC (Appendix J); e-Receipt Store (Appendix E); Audit Log (Appendix T); Owner Matrix 
(Appendix Y); Publication & Dashboards (Appendix S/AL); DPIA (Appendix R) 
Version: G-1.6.0 · Next review due: 30 days from publication 
Compatibility note: Keep all existing G-appendix text unless it directly conflicts with any 

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Normative rule below. Where conflicts exist, this version prevails and the change must be 
logged in the S-8 change-log. 
 
Why this matters (and why it hasn’t worked) 
Sanctions and remedies have too often leaned on titles and desk files rather than observed 
competence and field signals. Inconsistent thresholds, late reasons, unresolved 
contradictions, and slow appeals have dulled accountability. This appendix makes 
consequences proportionate, predictable and fair by standardising triggers, evidence, and 
timelines - anchored to artefacts that stand up in review. 
 
Fast take (read this first) 
• Four-rung Sanctions Ladder with evidence-based triggers; escalates when patterns 
persist. 
• Natural justice by design: right to reply and appeal; every decision and reasons 
hash-recorded (Appendix T). 
• Safety first: immediate suspension authority where risk to people is acute or serious 
fraud is likely. 
• Mandatory trio for consequential matters: R&W (H) + Contradiction Matrix (I) 
+ IRC (J); DSC file⇄field verification for contested facts. 
• Publication you can read: status, reason and what was fixed - never person-level 
data (Appendix S). 
 
Scope 
Covers: provider licensing/registration conditions; COORD/OPS licence classes; clinical 
safety domains (restraint, medication delegation, mealtime/IDDSI, seizure response); 
financial integrity (e-receipt / roster↔claim); and Navigator/Foundational handovers. Applies 
to actions by NDIA/Commission/Guardian/Tribunal/OPA/OPG/Regulator and contractual 
sanctions. 
 
The Sanctions Ladder (G-SL)  -  rungs, triggers, durations 
G-SL-1 Improvement Plan (IP) 
• Trigger: first substantiated breach; low risk; documentation gaps; missed tiles/SLAs. 
• Content: corrective actions (owners/dates); training/OSCE bookings; e-receipt catch-
up; DPIA patch if needed. 
• Window: 30-60 days. 
• Evidence: R&W optional; Contradiction Matrix if facts contested. 
• Publication: internal; aggregates only (S-Q tiles). 
G-SL-2 Conditional Operation (CO) 

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• Trigger: repeat breach or moderate risk; unresolved conflicts of interest; failed warm 
handovers; low doc_integrity_score. 
• Conditions: narrowed scope; Two-Key mandatory for named domains; DSC 
shadowing; enhanced reporting (S-Q10, S-Q11). 
• Window: 60-120 days. 
• Evidence: R&W + Matrix + IRC required; DSC verification recommended. 
• Publication: de-identified provider-family status + reasons digest. 
G-SL-3 Suspension (SUS)  -  partial or full 
• Trigger: serious risk of harm; restrictive-practice breaches; falsified records; 
unresolved high anomaly rate; unlicensed safety-critical acts. 
• Action: stop named services; appoint alternate second key; managed switching for 
affected participants. 
• Window: up to 6 months (review at 90 days). 
• Evidence: DSC report required; R&W + Matrix + IRC; OSCE/licensing status 
checked. 
• Publication: status + reasons digest; tiles flagged (S-Q03, S-Q11). 
• Immediate suspension authority (normative): where a DSC/decision-maker 
identifies acute risk to safety or probable serious fraud, suspension may be 
imposed immediately, with a reasons note issued within 5 business days and a 
review at 30-90 days. 
G-SL-4 Deregistration / Contract Termination (DRG) 
• Trigger: grave or recurring breaches; non-cooperation; retaliation; systemic fraud. 
• Action: revoke licence/registration; managed exit plan via Owner Matrix (Y). 
• Window: permanent; re-entry only via new application after stand-down + full 
licensing/OSCE. 
• Evidence: DSC + R&W + Matrix + IRC; integrity pack (e-receipt coverage, 
roster↔claim reconciliation, audit-log hashes). 
• Publication: formal public notice; dashboards updated next cycle. 
Automatic escalators (normative): 
• Failure to meet IP/CO milestones without approved variance. 
• Two consecutive quarters with doc_integrity_score < 70 or 
dsc_file_field_concordance < 80. 
• Sentinel events with no 72-hour review (S-Q01). 
 
Evidence Rules (what counts, how it is weighed)  -  normative 
Mandatory artefacts for any CO/SUS/DRG and for consequential decisions: 
1. Reasons & Weighing (Appendix H): issues → options → weights (H/M/L) → least-
restrictive analysis → decision/conditions → plain-language summary. 
2. Contradiction Matrix (Appendix I): material assertions; sources; weight; status 
(C/CT/U); action & owner/due; evidence links. 

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3. Independent-Reasoning Certificate (Appendix J): independent evaluation, least-
restrictive tests, SDM/communication access, MIS deviations, appeal-bundle 
initiated. 
4. DSC Verification: file⇄field check; shadowing notes; calibration status; integrity 
pack (e-receipts, roster↔claim, audit-log hash). 
5. Privacy/DPIA hooks (Appendix R): lawful basis; access rules; redaction plan. 
Weighing principles: 
• No single source determinative where contradictions exist. 
• Observed practice (DSC/OSCE/field) outranks uncorroborated paper. 
• E-receipt + roster↔claim + audit-log concordance ↑weight; unexplained gaps 
↓weight. 
• Person’s will and preferences (with communication access/AAC/Interpreter) must be 
captured and weighed explicitly. 
 
Timeliness & windows (normative) 
• Right-to-Reasons (lay): within applicable service guarantee; clock starts at decision 
notification. 
• Appeal bundle initiation: ≤ 10 business days from request (R&W, Matrix, 
schedules, audio/transcript request). 
• 72-hour learning review: mandatory after any restraint/sedation/PRN trigger. 
• Sanction review points: IP (≤60d), CO (≤120d), SUS (90d). 
• Status change publication: within 5 business days; dashboards update next cycle. 
 
Roles & independence (normative) 
• Decision-maker: Regulator/NDIA delegate/Guardian/Tribunal member (as 
applicable). 
• DSC: panel-appointed, conflict-screened; never provider-appointed; method 
published. 
• Second key: independent pairing via IPP; conflict screen logged; identity verified. 
• Separation: COORD independence from provision enforced; alternate second key 
required where conflicts persist. 
• Natural justice: before an adverse sanction (CO/SUS/DRG), provide the evidence 
pack and a reasonable opportunity to reply, except where urgent action is required for 
safety/fraud. All decisions and reasons are hash-recorded in the Audit Log 
(Appendix T) and an appeal pathway is stated in the notice. 
 
Tiles referenced in decisions (signals) 
Cite, where relevant (Appendix S): 
• Public: two_key_coverage (S-P01), r2r_on_time_rate (S-P03), doc_integrity_score 
(S-P06). 

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• QA: 72h_review_completion_rate (S-Q01), dsc_file_field_concordance (S-Q02), 
licensed_scope_coverage (S-Q03), e_receipt_coverage (S-Q10), 
roster_claim_anomaly_rate (S-Q11). 
 
What good looks like / Red flags 
Good 
• Decisions include R&W + Matrix + IRC; DSC pack attached; lay reasons readable; 
audit-log hash present. 
• Improvement Plans close on time; OSCE/licensing status visible; conflicts declared; 
Navigator warm handovers evidenced. 
• Publication shows updated aggregates; S-8 change-log complete; small-cell 
suppression applied. 
Red flags 
• Sanction without Matrix/IRC; contradictions unresolved or off-record. 
• Recurrent unlicensed safety-critical acts; missing e-receipts; audit-log gaps. 
• Falling two_key_coverage with rising time_to_second_key; doc_integrity_score < 70 
two quarters running. 
 
Where to get help / Artefacts & Templates 
• Appendix H: Reasons & Weighing (fillable shell) 
• Appendix I: Contradiction Matrix (registry tool) 
• Appendix J: Independent-Reasoning Certificate (IRC) 
• Appendix E: Two-party e-receipt schema 
• Appendix T: Audit Log Specification (hash/trace) 
• Appendix S / AL: Tiles & publication schema; change-log 
• Appendix Q: OSCE rubrics & licensing registry 
• Appendix Y: Owner Matrix & Escalation (close-out) 
 
Summary companion: Sanctions must be proportionate & predictable, uphold natural 
justice, escalate when patterns persist, publish outcomes that the public can read (no 
person-level data), and default to safety first. Use R&W + Matrix + IRC every time; 
bring in DSC when facts are contested; and make each decision audit-verifiable. 
 
Appendix H  -  Reasons & Weighting (R&W)  
Issues, evidence table with probative weight, applied tests, findings, remedies/actions. 
Owner: DSC Unit 
Interfaces: Independent Verification Standard; Contradiction Matrix; Complaints & 
Appeals; Sanctions Ladder; Truth-by-Design; Privacy/DPIA; Two-Key Register (IPP); e-

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Receipt store; Audit Log; Publication & Tiles (Appendix S); Navigator/Foundational 
Supports (where relevant) 
 
Why this matters (and why it hasn’t worked) 
Contested decisions often read like conclusions first, reasons later. Evidence is mixed 
together without showing what carries weight, contradictions aren’t resolved, and applied 
tests are unclear. Live practice (what actually happened) can diverge from curated files. This 
appendix information makes decisions auditable and fair: issues framed up front, evidence 
weighed transparently, contradictions resolved on the record, tests applied (including least-
restrictive), and actions that actually fix the problem - with artefacts that stand up in review 
(e-receipts, roster↔claim checks, DSC file-vs-field). 
 
Fast take (read this first) 
• Frame the issues before reading evidence. 
• Weigh each item on a 0-4 probative scale with a short rationale. 
• Resolve contradictions explicitly (who/what to prefer, and why) using the Contradiction 
Matrix. 
• Apply the tests (necessity, least-restrictive, lawfulness, proportionality, candour/integrity, 
privacy; add Two-Key/Independence and Warm Handover where relevant). 
• Write numbered findings that cite evidence IDs and weights. 
• Finish with remedies/actions (owner, deadline, verification). 
• Sign the Independent-Reasoning Certificate (named officer) and record the audit-log 
hash. 
• If an appeal is requested, start the bundle within 10 business days. 
 
1) Issues list (set the questions first) 
Number each question the decision must answer. 
Issue ID Question (plain English) Outcome needed 
I1 Did staff use restraint lawfully and only to prevent 
imminent harm on 15 Aug? Yes/No with reasons 
I2 Are claim variances a pattern requiring enforcement? Yes/No + stage 
I3 What immediate remedies are required? Actions with owners/dates 
I4 (if 
applicable) Was Two-Key obtained for this consequential decision? Yes/No + why; 
independence screen 
I5 (if 
applicable) Was a Navigator warm handover completed? Yes/No + evidence 
 
2) Evidence table with probative weight 
Use short, neutral descriptions. Weight each item before you write findings. 

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Probative scale: 0 Excluded • 1 Low • 2 Moderate • 3 High • 4 Determinative 
Weighting cues: directness; proximity in time; consistency/corroboration; source 
expertise/interest; chain-of-custody/integrity (e-receipt + roster↔claim + audit-log); 
method quality; plausibility; observed practice/DSC. 
Ev ID Description Source Date/Time Relates to 
(Issues) 
Weight 
(0-4) 
Why this weight (≤25 
words) 
E01 CCTV corridor clip (00:14-
00:17) 
Site 
system 
15-Aug 
14:03 I1 4 Direct, timestamped, 
no edits 
E02 Worker note (“brief hold 
~2 min”) 
Note 
system 
15-Aug 
16:40 I1 2 Late entry; vague 
timing 
E03 Two-party e-receipt (90 
min, community) App 15-Aug 
16:10 I2 3 Dual attested; minutes 
verified 
E04 Family statement Phone log 16-Aug I1 2 Partial view; consistent 
tone 
E05 Cross-check report (E3 
variances 9%) Integrity 1-31 Aug I2 3 System-generated; 
reproducible 
E06 
(opt.) 
DSC field observation 
memo DSC 17-Aug I1/I4 3 Observed practice 
aligns with E01 
 
3) Contradiction Matrix (resolve conflicts) 
Show conflicts and the resolution principle you applied (link to Appendix I row IDs). 
Conflict Items Resolution principle Preferred 
item Why 
Timing of 
hold 
E01 vs 
E02 
Direct, timestamped > late 
narrative E01 Video is contemporaneous 
and complete 
Minutes 
billed 
E03 vs 
roster 
Attested minutes with audit trail 
> roster estimate E03 Dual attestation + claim 
match 
 
4) Applied tests (state the test, then apply it) 
Tick Pass/Fail/Mixed and cite the evidence IDs you relied on. 
Test Standard Result Evidence 
relied on 
Notes (≤30 
words) 
Necessity & least-restrictive Emergency-only; 
prevent imminent harm Pass E01, E04, 
E06 
Hold brief; 
alternatives 
attempted 
Lawfulness/authorisation Named authority; time-
kept start/stop Mixed E01, E02 
Timing ok; 
authoriser not 
recorded 
Two-Key / Independence (if 
consequential) 
Second key via IPP; 
conflicts screened; 
timestamps 
Fail/Pass E06, IPP log 
Second key 
missing; require 
now 
Candour & integrity Truth-by-Design 
artefacts present Mixed E03, E05 Variance pattern 
needs remedy 

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Test Standard Result Evidence 
relied on 
Notes (≤30 
words) 
Privacy/DPIA 
Minimum data 
published; suppression 
rules 
Pass  -  No person-level 
data 
Warm handover (Navigator) 
(if applicable) 
Artefact + contact + 
appointment kept Pass/Fail E-receipt 
handover flag 
Three elements 
verified 
 
5) Findings (numbered, with reasons) 
Write short, numbered findings. Each finding must cite the evidence IDs and weights that 
carried it. 
1. The restraint on 15 Aug was necessary and least-restrictive (E01, w4; E04, w2; E06, 
w3). 
2. Authorisation records were incomplete (E02, w2): authoriser not captured at the time 
of event. 
3. Claim variances constitute a pattern requiring Stage 1 Improvement Notice (E05, 
w3; E03, w3). 
4. (If applicable) This consequential decision lacked Two-Key; a compliant second key 
must be obtained prior to enactment (IPP entry required). 
 
6) Remedies & actions (owner, deadline, verification) 
Tie actions directly to findings. Each action needs a verification step. 
No. Action Owner Due Verification 
A1 Add start/stop & authoriser fields to 
Restrictive Practice Log; retrain staff Manager 14 
days 
Audit 10 events; 0 
missing fields 
A2 Issue Stage 1 Improvement Notice on 
claim variances; CAP with roster rules Governance 10 
days 
Match-rate ≥98% for 
2 fortnights 
A3 Family debrief using 72-Hour Review; 
update Fade Plan IDC Lead 3 
days 
Review held; plan 
updated 
A4 (if Two-
Key failed) 
Obtain second key via IPP; record 
Reasons & Weighting for co-sign Coordinator 24 h IPP timestamps + 
R&W attached 
A5 (if 
handover due) 
Complete Navigator warm handover 
(artefact + contact + appointment) COORD 7 
days 
E-receipt handover 
flag present 
 
7) Plain-English Reasons (one paragraph) 
On 15 Aug, staff briefly held John to stop immediate harm. Video shows the hold started at 
14:03 and ended soon after. Alternatives were attempted first. However, the authoriser’s 
name was not recorded at the time. Claims data shows a recent pattern of minutes variances. 
We have ordered fixes to authorisation capture, a time-boxed improvement plan on claims, 
and a debrief with the family to update the fade plan. (If relevant: A second decision-maker 

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will now co-sign this decision under the Two-Key rule; your Navigator handover is booked 
and confirmed.) 
 
8) Independent-Reasoning Certificate (sign-off) 
I confirm that I identified the issues before reading conclusions, weighed each evidence item 
using the stated scale, resolved contradictions, applied the listed tests, and wrote findings that 
cite weighted evidence. I have initiated the appeal bundle within 10 business days if 
requested, and recorded the audit-log hash. 
• Decision officer (name, role, signature, date) 
• Second reviewer (name, role, date) 
• Conflicts declared: ___ 
• Records kept: evidence list, tables, notes, and this certificate filed to audit log. 
 
What good looks like / Red flags 
Good: issues framed first; weights justified in one line; contradictions resolved using the 
Matrix; tests applied (incl. Two-Key/Independence and Warm Handover where relevant); 
numbered findings that point to evidence IDs; actions with owners and verification; reasons 
readable by families; audit-log hash present. 
 
Red flags: conclusions without weights; “balance of probabilities” stated without showing 
why; contradictions ignored; actions like “staff to be vigilant”; no Two-Key where required; 
no e-receipt or roster↔claim reconciliation. 
 
Quick scripts 
• Explaining R&W to a family: “We list the questions, weigh each piece of evidence, resolve 
conflicts, apply the rules, then write findings you can read. You’ll see which evidence we 
relied on.” 
• Explaining a downgrade/upgrade: “We changed our view because E05 (system report, 
weight 3) showed a broader pattern than the notes suggested.” 
• Explaining Two-Key: “For big decisions, a second independent decision-maker must co-
sign. We record who, why, and when.” 
 
Where to get help / Artefacts & Templates 
• R&W One-Pager (Issues → Evidence table → Contradiction Matrix → Tests → Findings 
→ Actions) 
• Independent-Reasoning Certificate 
• Weights rubric (0-4 cues and examples) 
• Plain-English Reasons block (with character limit) 
• Contradiction Matrix (Appendix I) · Truth-by-Design · Privacy/DPIA · Sanctions Ladder · 
Publication & Tiles (Appendix S) 

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Summary companion. Decisions rely on the governing sections named in the 
Independent Verification Standard, Truth-by-Design and Privacy/DPIA. Use this 0-4 
weighted method, show how conflicts were resolved, prove integrity (e-
receipt/roster↔claim/audit-log), apply least-restrictive, and write reasons the person 
can read. 
 
Appendix I  -  Contradiction Matrix 
Identify conflicts, apply resolution principles, record the preferred evidence and confidence. 
Owner: DSC Unit 
Interfaces: Reasons & Weighting (Appendix H); Independent Verification Standard; 
Complaints & Appeals; Sanctions Ladder; Truth-by-Design; Audit Log Spec; Privacy/DPIA; 
Two-Key Register (IPP); e-Receipt store; Navigator/Foundational Supports (handover 
artefacts) 
 
Why this matters (and why it hasn’t worked) 
Disputes derail when conflicting accounts are listed but not resolved. Decisions then look 
arbitrary or biased. The Contradiction Matrix forces a clear method: name the conflict, apply 
standard resolution principles, state which evidence prevails (and why), and record the 
confidence so others can audit the reasoning. It also brings observed practice (DSC/file-vs-
field) and integrity hooks (e-receipts, roster↔claim, audit-log hashes) into the resolution - so 
titles and averages don’t overrule facts. 
 
Fast take (read this first) 
• Log each specific conflict (not the whole case). 
• Compare items by quality, proximity, consistency, independence and integrity hooks - not 
by job title or volume. 
• Apply the resolution principles (below) and write the one-line reason. 
• Record a confidence level and any follow-ups needed to lift it (e.g., DSC shadow, IPP 
check). 
• Feed the result straight into Appendix H (R&W) findings and note the C-ID you relied on. 
 
Resolution principles (use these consistently) 
1. Direct over derivative: primary evidence (video, telemetry, contemporaneous 
record) > recollection or summary. 
2. Contemporaneous over retrospective: recorded at/near the time > late entry. 
3. Objective method over impression: measured/validated > opinion without method. 
4. Complete chain-of-custody over partial: intact metadata/logs > cropped/edited or 
missing context. 

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5. Consistent & corroborated over isolated: aligns with other independent sources > 
stands alone. 
6. Competence & role relevance: trained observer in scope > bystander outside scope. 
7. Lower conflict-of-interest over interested party: neutral source > party with stake. 
8. Plausibility & mechanism: fits human factors/clinical reality > implausible claim. 
9. Reproducibility: system can re-create the figure/state > one-off calculation. 
10. If still tied → seek more: escalate for independent verification (DSC) or Two-
Key/IPP re-check; mark confidence Low until resolved. 
(Tip: Where integrity artefacts exist, prefer items with e-receipt + roster↔claim + audit-log 
concordance, unless a higher-quality primary record contradicts them.) 
 
Example Template  -  Contradiction Matrix (one row per conflict) 
C-ID Conflict (plain 
English) 
Evidence 
items 
compared 
(IDs from 
Appx H) 
Key 
resolution 
principles 
(nos.) 
Preferred 
evidence 
(ID) 
Why 
preferred 
(≤25 words) 
Confidence 
(High/Mod/Low) 
Follow-ups to 
lift confidence 
(owner/date) 
C01 How long did 
the hold last? 
E01 CCTV, 
E02 late 
note 
1,2,4 E01 
Direct video, 
timestamped, 
intact metadata 
High - 
C02 
Were 120 mins 
claimed 
appropriately? 
E03 e-
receipt, E06 
roster, E07 
family call 
3,9,5 E03 
Dual-attested; 
system-timed; 
claim match 
Mod 
Supervisor to 
confirm travel 
split by 12/09 
C03 Was interpreter 
offered? 
E10 triage 
form, E11 
family 
statement 
2,5,7 E10 
Completed at 
time; 
corroborated 
by ED SMS 
log 
Mod 
Check ED 
kiosk CCTV 
still 11/09 
C04* Was Two-Key 
obtained? 
IPP log, E02 
note, DSC 
memo 
2,6,7 IPP log 
Independent 
pairing + 
timestamps 
High - 
C05* 
Navigator 
warm 
handover 
completed? 
Handover 
artefact, 
contact 
note, 
booking 
record 
3,5,7 Artefact 
bundle 
All three 
elements 
present 
High - 
Add “” to flag conflicts that gate a consequential decision (Two-Key/Warm-handover).* 
Keep conflicts atomic. If several points are entangled, create C-IDs C03a, C03b… 
 
Conflict types (tick one per row) 
• Fact/time (what/when/how long) 
• Attribution/role (who did what) 
• Method/measurement (minutes, dosage, billing) 
• Law/threshold (authorisation, necessity, Two-Key obtained?) 

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• Context/translation (meaning; interpreter/AAC) 
• Handover/continuity (Navigator warm handover) 
 
Confidence guide (how to rate) 
• High: preferred item is direct/contemporaneous with intact chain; ≥2 principles favour it; 
no credible rebuttal. 
• Moderate: strong but one material weakness (e.g., partial context) or a pending 
corroboration (e.g., DSC shadowing). 
• Low: tie not broken; further verification required (then escalate via Independent 
Verification Standard and/or IPP check). 
 
How to run the matrix (step-by-step) 
1. List conflicts you must resolve to answer the Issues (Appendix H). 
2. Attach the items being compared (use evidence IDs from the R&W table). 
3. Apply principles (numbers only in the table; keep the Why line ≤25 words). 
4. Select preferred item and record the reason. 
5. Rate confidence; add follow-ups if <High (e.g., DSC file-vs-field, audit-log hash 
check, IPP independence screen). 
6. Port results directly to Appendix H: cite the C-ID in your numbered findings. 
 
What good looks like / Red flags 
Good: conflicts are specific; principles are cited; preference reasons are short and neutral; 
most rows end High; unresolved rows have explicit follow-ups with owners/dates; integrity 
hooks referenced. 
 
Red flags: “both could be true” with no action; status-based deference (“manager said”); 
long prose without principle numbers; no link back to evidence IDs; ignoring IPP/Two-Key 
or handover artefacts when in scope. 
 
Micro-scenarios (worked) 
• Roster vs e-receipt minutes: Roster says 120; receipt says 90. Preferred: receipt (system-
timed, dual-attested). Follow-up: confirm travel code split. Confidence: Mod → High once 
adjusted. 
• Note vs CCTV on restraint start: Late note “~2 min”; CCTV shows 43 seconds. 
Preferred: CCTV (1,2,4). Confidence: High. 
• Family recollection vs medication chart: Family says sedative at 18:00; chart shows 
19:10 with barcode scan. Preferred: chart (3,4,9). Confidence: High; offer family timeline 
explanation. 
• Two-Key obtained? IPP shows second-key at 10:14; progress note says “awaiting co-
sign”. Preferred: IPP log (2,6,7). Confidence: High. 

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• Warm handover complete? Artefact + contact call + first booking kept present. Preferred: 
artefact bundle. Confidence: High. 
 
Quick scripts 
• Explaining a resolution to a family: 
“Two records disagreed on how long the hold lasted. We preferred the timestamped video 
recorded at the time. Your account helped explain what led up to it.” 
• Explaining a tie to a provider: 
“The evidence is split. We’ve marked confidence Low and requested an independent check. 
Until then, we won’t rely on that point to escalate sanctions.” 
 
Where to get help / Artefacts & Templates 
• Contradiction Matrix table (blank) 
• Principles one-pager (with short examples) 
• Confidence rubric (High/Mod/Low) 
• Independent verification request form (DSC) 
• IPP independence screen (Two-Key) · e-Receipt schema · Audit-log hash check 
 
Summary companion. Use the Matrix on every material conflict. Prefer direct, 
contemporaneous, reproducible evidence with integrity hooks; escalate ties to DSC or IPP; 
write one-line reasons; carry the C-ID into Appendix H; and make the record audit-
verifiable. 
 
 
Appendix J  -  Independent-Reasoning Certificate (IRC) 
Owner: DSC Unit 
Interfaces: Reasons & Weighting (Appendix H); Contradiction Matrix (Appendix I); 
Independent Verification Standard; Complaints & Appeals; Truth-by-Design; Audit Log 
Spec; Privacy/DPIA; Two-Key Register (IPP); e-Receipt store; Publication & Tiles 
(Appendix S); Navigator/Foundational Supports. 
 
Why this matters (and why it hasn’t worked) 
Contested decisions lose trust when they look like opinions dressed as findings. Families 
cannot see who took responsibility, what method was used, or whether conflicts of evidence 
were resolved fairly. The IRC is a named, auditable sign-off that the R&W method was 
followed, contradictions were resolved with stated principles, tests were applied (including 
least-restrictive), conflicts were declared, actions are verifiable, and the record is anchored 
to integrity artefacts (e-receipts, roster↔claim checks, audit-log hash, DSC file-vs-field). 

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Fast take (read this first) 
• Use the IRC for any contested or high-impact decision (safety, sanctions, funding 
integrity, complaint outcomes, tribunal prep). 
• One page to read; evidence bundle behind it. 
• Must cite: Issues list, Evidence IDs & weights, Contradiction Matrix IDs, Applied tests, 
Numbered findings, Actions with owners/dates. 
• Two signatures (decision officer + second reviewer). 
• File to the audit log with a provenance hash; share a plain-English summary with the 
person/representative. 
• If an appeal is requested, start the bundle within 10 business days. 
• Where applicable, confirm Two-Key (IPP) and Navigator warm handover status. 
 
When the IRC is required (minimum triggers) 
• Use of restraint or seclusion-like practice is disputed by any party. 
• Sanctions Ladder Stage ≥ 2, or payment holds/suspension. 
• Complaints where findings rely on conflicting accounts. 
• Decisions that limit access/participation or change living arrangements. 
• Any appeal or tribunal preparation package. 
• Consequential decisions requiring Two-Key or Navigator handover. 
 
Example Template  -  Independent-Reasoning Certificate (complete and file) 
A. Case header 
• Case/Ref ID: ____ Provider/Team: ____ Person/Rep: ____ 
• Decision scope (1 line): ____________________________________ 
• Decision date/time (local): / : ___ 
• Evidence bundle hash (SHA-256): __________________________ 
• Audit-log event ID: __________________ 
B. Method check (tick all that apply / mandatory ticks required) 
☐ Issues were listed first (Appendix H §1) 
☐ Evidence items were described neutrally and weighted 0-4 (H §2) 
☐ Conflicts were resolved in a Contradiction Matrix with principles cited (Appendix I) 
☐ Applied tests used: necessity, least-restrictive, lawfulness, proportionality, 
candour/integrity, privacy 
☐ Two-Key status checked (IPP independence, timestamps) where consequential 
☐ Navigator warm handover checked (artefact + contact + appointment) where applicable 
☐ Numbered findings cite Evidence IDs and weights 
☐ Remedies/actions specify owner + due date + verification step 
☐ Plain-English Reasons prepared for the person/representative 
☐ Privacy/DPIA checks completed; small-cell suppression considered for any publication 
☐ DSC file-vs-field verification included where facts were contested 

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C. References (write IDs, not prose) 
• Issues considered: I__ , I__ , I__ 
• Evidence relied upon (IDs & weights): E__ (w__), E__ (w__), E__ (w__) … 
• Contradictions resolved: C__ , C__ , C__ 
• Applied tests (results): Necessity/Least-restrictive (P/F/M); Lawfulness (P/F/M); 
Candour/Integrity (P/F/M); Privacy/DPIA (P/F/M); Two-Key (P/F/M/NA); Navigator 
handover (P/F/M/NA) 
D. Numbered findings (≤5 lines total; cite IDs & weights) 
1.  
2.  
3.  
E. Remedies & actions (each must be verifiable) 
 
No. Action Owner Due Verification (what proves it) 
1     
2     
3     
 
F. Conflicts of interest & participation 
• Decision officer conflict declared? ☐ No ☐ Yes → details: __________________ 
• Second reviewer conflict declared? ☐ No ☐ Yes → details: __________________ 
• Person/Representative involved? ☐ Yes (how: meeting/phone/written) ☐ No (why: 
risk/unavailable) 
• Interpreters/AAC used? ☐ Yes (type: _______) ☐ Not required 
G. Plain-English Reasons (for the person/representative)  -  ≤140 words 
H. Natural justice & appeal 
☐ Evidence pack provided and right to reply offered (unless urgent safety/fraud) 
☐ Appeal pathway stated; appeal bundle initiated within 10 business days if requested 
I. Sign-off 
I certify that this decision followed the Independent Verification method and that findings are 
supported by the weighted evidence cited above. 
• Decision officer (name, role, signature): __________________ Date: / 
• Second reviewer (name, role, signature): __________________ Date: / 
J. Filing 

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☐ Filed to audit log with evidence bundle and hash 
☐ Shared with person/representative in accessible format (record method) 
☐ Publication status set per policy (Appendix S suppression rules) 
 
Grounds that can invalidate a decision (use as a self-check) 
• Issues not stated up front; no link from findings to Evidence IDs/weights. 
• Contradictions listed but not resolved with stated principles. 
• Required tests not applied or misapplied (least-restrictive, lawfulness, candour/integrity, 
privacy). 
• Two-Key not obtained where required; Navigator handover missing where mandated. 
• Undisclosed conflict of interest. 
• Evidence added/changed after sign-off without an addendum in the audit log. 
• Privacy breach (identifiers published; small cells exposed). 
 
What good looks like / Red flags 
Good: short certificate; specific IDs; clear tests; actions with verification; family can read the 
Reasons; audit-log entry present; Two-Key/IPP and Navigator checks completed when in 
scope. 
 
Red flags: prose without IDs; “balance of probabilities” asserted without weights; no second 
signature; publication before DPIA check; missing small-cell suppression. 
 
Micro-scenarios (worked) 
• Restraint dispute: Issues I1-I3 set. CCTV (E01, w4) vs late note (E02, w2) resolved in 
C01 using principles 1,2,4. Findings: lawful brief hold; authorisation field missing → Action 
to fix log; 72-hour review with family. 
• Payment hold: Cross-check report (E05, w3) + receipts (E03, w3) show sustained E3 
variances. Findings: Stage-2 Enforcement Warning → Actions: CAP with roster rules; 
match-rate ≥98% for 2 fortnights (verification). 
• Interpreter complaint: Triage form (E10, w3) + SMS log (E12, w3) outweigh recollection 
(E11, w2) via principles 2,5,7. Finding: offer made and declined; mandate proactive 
communication plan. 
• Two-Key check: IPP shows second-key at 10:14; progress note says “awaiting co-sign”. 
Finding: Two-Key satisfied at 10:14; condition: maintain IPP timestamps for future 
decisions. 
• Navigator handover: Artefact + contact + appointment kept present. Finding: continuity 
requirement met; no delay to supports. 
 
Quick scripts 

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• To a family: “This certificate shows exactly how we reached the decision - what evidence 
counted most, how we resolved differences, and what we’re changing by when.” 
• To a provider manager: “Sign your IRC only when every finding points to an Evidence ID 
and a weight. If you can’t do that, you’re not finished.” 
 
Where to get help / Artefacts & Templates 
• IRC one-page form (fillable) 
• Second-reviewer checklist 
• Publication decision aid (what goes public; suppression rules) 
• Audit-log filing checklist 
• R&W template (Appendix H) · Contradiction Matrix (Appendix I) · Truth-by-Design · 
Privacy/DPIA 
 
Summary companion. Decisions rely on the governing sections named in the 
Independent Verification Standard, Reasons & Weighting Template, Truth-by-Design 
and Privacy/DPIA. 
 
Appendix K  -  Accessible Plan Pack (Plain English + Easy Read) 
Owner: Coordination & Practice 
Interfaces: Choice & Control; Communication Access; Safety & Restrictive Practices; 72-
Hour Review & Fade Plan; Participation/CPI; Handover & Medication Reconciliation; E-
Receipts (family view); Complaints & Appeals; Privacy/DPIA. 
Why this matters (and why it hasn’t worked) 
Plans are often long, legalistic and out of date. Families and new staff can’t quickly see what 
matters today, who to call, or how to act in a crisis. This pack turns the person’s plan into 
clear, short pages that the person can understand and use - Plain English for detail, Easy Read 
for at-a-glance action - so goals move, risks drop and rights are respected. 
Fast take (read this first) 
• The pack has two companion formats: 
1. Plain English Summary (2-4 pages) for detail; 
2. Easy Read One-Pagers (large type + icons) for daily use. 
• Keep language concrete. Define acronyms once or avoid them. 
• Update on any major change and at least quarterly. 
• Provide in the person’s preferred format/language (interpreter/Auslan/audio/Braille). 
• Include who does what, how to reach them, and how the person says yes/no. 
• Store at point-of-care and in the record; share with the person/representative. 
Scope 

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All participants and settings (home, community, day program, school, work, health 
interfaces). Digital and print versions must mirror each other. Where time limits or legal tests 
are referenced (e.g., restraint rules), copy them verbatim from the governing standards. 
 
What’s in the pack (content checklist) 
1) Plain English Plan Summary (2-4 pages) 
• About me (2-3 lines): strengths, interests, what matters most. 
• Communication access: how I say yes/no; AAC/interpreters; words/phrases that help. 
• Goals this quarter (max 5): each with steps, allies, and dates. 
• Weekly rhythm: where I go, when, transport plan, community roles. 
• Health & safety notes: allergies, seizures/choking risks, pain plan, emergency 
contacts. 
• Supports & roles: who does what (family, IDC lead, specialists). 
• Rights & decisions: consent preferences; who can speak for me and when. 
• How to raise a concern: easy path to complaints/appeals. 
• Last updated / next review date; who agreed (signatures/attestation options). 
2) Easy Read One-Pagers (each stand-alone) 
• My day & week (big calendar tiles; pictures/icons). 
• How to talk with me (yes/no, key words/pictures/device). 
• Where I go in my community (maps/tiles; CPI-friendly). 
• People & permissions (photos/names/roles; who to call). 
• If I’m upset (first signs → what helps first → who leads). 
• My health basics (allergies, medicine times, red flags). 
• My rights (choice, privacy, complaint buttons). 
• Photo & data sharing (what I agree to / don’t). 
• Switching providers (how to take my info with me). 
 
Build and maintain (step-by-step) 
1. Prepare 
o Confirm preferred language/format; book interpreter/Auslan if needed. 
o Gather current plan, 72-Hour Review/Fade Plan, health passport, weekly 
schedule. 
2. Draft the Plain English Summary 
o Short sentences (avg ≤18 words). 
o Use must/when/unless for rules; avoid jargon. 
o Copy any legal thresholds verbatim from standards. 
3. Create Easy Read One-Pagers 
o 16-18 pt font minimum, left-aligned; icons/pictures next to text. 
o One idea per line; tick-boxes where actions/choices apply. 
o Offer audio/voiceover QR if helpful. 
4. Check with the person/representative 
o Walk through each page; confirm words and pictures feel right. 
o Record consent preferences (photo/data sharing, publication). 
5. File and share 

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o Store in the person’s record and give copies (print/digital). 
o Place the How to talk with me and If I’m upset pages at point-of-care. 
6. Keep it live 
o Update after any 72-Hour Review, health change, or goal shift. 
o Quarterly huddle: refresh weekly rhythm and roles. 
 
Formatting & accessibility rules 
• Plain English: Year-11/12 readability; headings, bullets, white space. 
• Easy Read: Year-6-8 readability; pictures/icons; minimal text; no ALL CAPS. 
• Provide translations; Auslan video for key pages where relevant. 
• Offer audio versions; large-print and Braille on request. 
• Use person-first language unless the person states otherwise. 
 
What good looks like / Red flags 
Good: one short pack everyone uses; person can point to choices; staff can act on first signs; 
community roles visible; updates are dated and signed. 
Red flags: 30-page plans no one reads; acronyms everywhere; no yes/no method; out-of-date 
contacts; no copy at point-of-care; no evidence of the person’s voice. 
 
Micro-scenarios (worked) 
• New staff on night shift: Reads How to talk with me and If I’m upset pages; uses the 
exact calming phrase and headphones; no restraint needed; logs minutes as zero. 
• Switching providers: Person uses Switching providers page; coordinator exports pack 
+ receipts history; new team is ready on Day 1 with weekly rhythm set. 
• ED visit: Family hands over My health basics and Communication pages; interpreter 
requested; sedation avoided; meds reconciled within 72 hours. 
 
Quick scripts 
• Starting the pack: “We’re making a short set of pages that show what matters to you, 
how you like to communicate, and what your week looks like. It should be easy to 
read.” 
• Checking consent: “Do you want photos in your pack? We can use pictures, drawings, 
or text only. You can change your mind any time.” 
 
Privacy, consent & sharing 
• Record who agreed, how (tap/PIN/biometric/verbal-witnessed/alt-comm), and 
date/time. 
• Store only what’s needed; keep addresses/phone numbers off public-facing copies. 
• Use small-cell suppression in any aggregated publication. 
• Renewal of consent at each quarterly update or when circumstances change. 

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Where to get help / Artefacts & Templates 
• Plain English Plan  -  2-4 page template 
• Easy Read One-Pager set: My day & week / How to talk with me / Where I go / 
People & permissions / If I’m upset / My health basics / My rights / Photo & data 
sharing / Switching providers 
• Consent & attestation form (accessible options) 
• Quarterly update checklist 
• Translation/Auslan/audio request form 
 
Summary companion. Decisions rely on the governing sections named in the Choice & 
Control Standard, Communication Access policy and Privacy/DPIA. 
 
Appendix L  -  Weekly Community Schedule & Presence/Participation 
Tracker 
Owner: Coordination & Practice. Service Model Standards. 
Interfaces: Choice & Control; Accessible Plan Pack (Appendix K); E-Receipts (Appendix 
E); Roster↔Claim Cross-Checks (Appendix F); Dashboards (Participation/CPI); Transport & 
Costs; Privacy/DPIA. 
Why this matters (and why it hasn’t worked) 
People drift back indoors when weeks aren’t planned with real places, roles and allies. 
Rosters fill time, not lives; notes say “community access” without showing where, who with, 
or what changed. This schedule and tracker make participation visible and repeatable - so 
variety grows, roles deepen, and crises fall. 
Fast take (read this first) 
• Build a one-week rhythm with named places, roles, allies and transport. 
• Link every outing to a quick e-receipt so minutes and participation tags flow to 
dashboards. 
• Track three numbers: sessions out-of-home per week; variety index (distinct 
places/activities per month); role depth (observer → member → helper → paid). 
• Review weekly in shift huddles; update monthly (or after any life change). 
• Use plain language and the person’s preferred format (Easy Read available). 
Scope 
All services and settings. Works for individuals and small groups. Use with the 
person/representative in co-design. 
 

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Part 1  -  Weekly Community Schedule (co-design and print) 
Fields to complete (per slot): 
Day | Time window | Place/venue | Role (observer/member/helper/paid) | Purpose/goal link | 
Ally/contact | Transport (to/from) | Costs/budget note | Accessibility needs (AAC, ramps, 
quiet space) | Backup plan (bad weather/closed) | E-receipt link/QR 
Example (snippet): 
Mon 10:00-12:00 | Oak St Men’s Shed | Member | Woodwork bench task (Goal 2) | Joe 
(volunteer) | Bus 705 / return with Mum | $5 materials | Ear defenders | If noisy → library 
craft | [QR] 
Build steps (30-40 min): 
1. Map places and people the person actually likes; add one new place to trial. 
2. Set transport (route, who drives, pickup point). 
3. Confirm access supports (AAC, yes/no card, interpreter booking). 
4. Write a short purpose line per slot (why we’re going). 
5. Add a simple backup plan for each slot. 
6. Print for the fridge and point-of-care; save to the record. 
 
Part 2  -  Participation Tracker (method and fields) 
The three numbers (definitions) 
1. Sessions out-of-home per week  -  count from e-receipts tagged domain=community 
(median per person). 
2. Variety index (per month)  -  distinct places/activities visited (from venue/activity 
codes). 
3. Role depth mix  -  share of sessions tagged observer/member/helper/paid. 
Recording (minimum fields per session) 
• Date | Venue/activity | Role depth | With whom (ally/peer) | Minutes (from e-receipt) | 
Notes (what changed / next step) 
Monthly summary (team view) 
• Sessions/week (median): ___ 
• Variety index (distinct venues/activities): ___ 
• Role depth mix: observer __% | member __% | helper __% | paid __% 
• New places tried: ___ | Stuck spots (why): ___ 
• Next month’s push (one line): ___ 
Targets (90-day horizon, set with the person) 
• Sessions/week ≥ ___ 
• Variety index ≥ ___ distinct places 
• Role depth: ≥ ___% at member or higher 
• Named community role(s): ___ by ___/____ 

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What good looks like / Red flags 
Good: names of real places; allies listed; transport locked in; receipts arrive same day; 
numbers move up over 90 days; backup plans prevent cancellations. 
Red flags: “community access” with no venue; cancelled slots with no backup; all observer 
roles; receipts batched days later; zero growth in variety. 
 
Micro-scenarios (worked) 
• Quiet joiner → active member: Library visit becomes “volunteer shelf-straightener” 
on Wednesdays; role tag moves from observer→member; variety index +1; calmer 
afternoons at home. 
• Weather fallback: Park walk washed out; backup “indoor pool” used; e-receipt shows 
domain=community; minutes preserved; streak of three weeks without cancellation 
continues. 
• Transport fix: Two missed sessions due to late bus → switch to community carpool 
with neighbour; sessions/week returns to target. 
 
Quick scripts 
• Explaining the plan: “This is your week in places you choose, with people who know 
you. Each visit has a purpose and a backup plan.” 
• Setting the next step: “You liked the Men’s Shed. Next week, do you want to try a 
small bench task with Joe as your helper?” 
 
Data, privacy & linkage 
• Use pseudonym keys on the tracker; names and contacts stored in the secure 
directory. 
• Addresses aren’t shown on public dashboards; publication uses coarse geography and 
suppression. 
• The schedule page includes a QR to open the e-receipt screen for that slot (fast 
capture, fewer errors). 
 
Where to get help / Artefacts & Templates 
• Weekly Community Schedule (fillable)  -  single-page planner with QR placeholders 
• Participation Tracker (individual/monthly)  -  sheet + CSV headers 
• Role Depth Guide  -  observer/member/helper/paid (examples) 
• Transport & Backup Planner  -  routes, contacts, contingencies 
• Icon set for Easy Read (places, roles, supports) 
 

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Summary companion. Decisions rely on the governing sections named in Choice & 
Control, Participation/CPI, and Privacy/DPIA. 
 
 
Appendix M  -  Switching Protocol & Exit/Entry Data Set 
Owner: Coordination & Integrity 
Interfaces: Choice & Control; Accessible Plan Pack (Appendix K); Weekly Community 
Schedule & Participation Tracker (Appendix L); E-Receipts (Appendix E); Roster↔Claim 
Cross-Checks (Appendix F); Handover & Medication Reconciliation (Appendix D); 
Privacy/DPIA; Complaints & Appeals; Sanctions Ladder. 
Why this matters (and why it hasn’t worked) 
Families get stuck with providers because the exit is messy: missing information, slow 
transfers, and fear of retaliation. People lose weeks of participation, medicines are duplicated, 
and billing disputes drag on. A clear switching protocol with a standard exit/entry data set 
makes transfers fast, safe and verifiable - so the person’s life keeps moving while 
organisations change. 
Fast take (read this first) 
• Person choice first. Switching must be supported, not blocked. 
• Two packs, one week: Exit Pack from the old provider; Entry Pack stood-up by the 
new provider - both due inside 5 business days of notice. 
• Minimum data set is standardised (below) and travels in a secure bundle with an audit 
hash. 
• Continuity window: weekly schedule continues; medications reconciled within 72 
hours of entry. 
• Money & minutes: final claims locked to the roster↔receipt truth; disputes handled 
separately from care. 
• No retaliation. Any obstruction triggers governance review and, where needed, the 
sanctions ladder. 
Scope 
All provider switches (voluntary or directed), including partial switches (e.g., behaviour 
support only). Applies across home, community, day programs, respite/short-stay and health 
interfaces. 
 
The Exit/Entry Data Set (minimum fields) 
Single JSON/CSV bundle + PDFs of human-readables. Identities use pseudonym keys; 
directory holds names. 
A. Person & Authority 
• person_psn; preferred name; date of birth (YYYY-MM-DD) 

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• legal authority (self / nominee / guardian / parent); contacts (phone/email) 
• consent record (mode, timestamp, scope for sharing) 
B. Communication Access 
• yes/no method; AAC devices/apps; interpreters/ Auslan needs; words/phrases that 
help 
C. Plan Essentials (Plain English) 
• top 5 goals (90-day horizon) with next steps 
• rights & preferences (photo/data sharing, privacy) 
D. Weekly Community Schedule 
• next 2 weeks of slots (day/time, venue, role, ally/contact, transport, backup plan) 
E. Participation/CPI Snapshot (last 90 days) 
• sessions/week (median); variety index; role-depth mix 
F. Health & Safety 
• allergies/adverse reactions; risk flags (seizure/choking/diabetes etc.) 
• last 72-hour review summary if any; current Fade Plan one-pager 
• restrictive-practice authorisations (if applicable), with start/stop/expiry 
G. Medicines (reconciled list) 
• name/strength/route/frequency/indication; start/stop; prescriber; pharmacy contact 
• PRNs with clear indication/max dose; next review dates 
H. Equipment & Access 
• issued equipment/consumables; ownership; service dates; keys/codes handback list 
I. Records & Integrity 
• e-receipt history pointer (secure link/IDs); outstanding E-codes pending courtesy-
check 
• last 90-day claim/roster match-rate; exceptions unresolved (IDs only) 
• audit-log hash of the exiting bundle 
J. Contacts & Roles 
• who does what (IDC lead, coordinator, clinicians, family allies) with direct contacts 
 
Switching steps (who does what, with timeframes) 

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1. Notice & consent (Day 0) 
o Person/rep gives written notice (or decision recorded). 
o Old provider confirms no-retaliation clause and nominates a switching lead. 
o New provider assigns an entry lead; both acknowledge timelines. 
2. Exit Pack (≤5 business days)  -  Old provider 
o Assemble the Exit/Entry Data Set (A-J) and encrypt bundle. 
o Provide Plain English + Easy Read copies (Appendix K). 
o Freeze rostered sessions beyond the agreed end date; cease new bookings. 
o Run final roster↔receipt sweep; flag any exceptions (do not hold up care). 
3. Entry Pack (≤5 business days, can overlap)  -  New provider 
o Stand up weekly schedule for two weeks (Appendix L). 
o Book medication reconciliation within 72 hours of first shift (Appendix D). 
o Confirm staff competence/OSCE currency for safety tasks. 
o Load consent settings and privacy preferences. 
4. Continuity window (Weeks 1-2) 
o Person’s usual places continue with named allies; transport confirmed. 
o Any restrictive-practice plan is honoured exactly; timing/logs continue. 
o E-receipts flow from Day 1; family view live. 
5. Settlement & close-out (≤20 business days) 
o Old provider submits final claims; disputes routed to governance without 
impacting support. 
o Keys, equipment and data directories reconciled and signed off. 
o New provider confirms first 30-day check-in meeting date. 
 
SLAs & escalation 
• Exit Pack late → 2-day grace → governance notification; Stage 1 Improvement 
Notice if pattern. 
• Data incomplete (missing meds, risk flags, restrictive-practice plan) → same-day 
escalation; pause only the unsafe element, not all supports. 
• Retaliation signals (cancelled shifts, gatekeeping venues, negative commentary) → 
immediate Stage 3 payment hold on offending categories while continuity plan 
activates. 
• Billing disputes → handled in integrity channel; care continues. 
 
What good looks like / Red flags 
Good: both packs delivered on time; person continues routine in Week 1; meds reconciled 
≤72h; receipts match; disputes handled without service gaps. 
Red flags: “we can’t share that” without lawful basis; vague plans; lost devices; unexplained 
cancellations; staff without required competence. 
 
Micro-scenarios (worked) 
• Partial switch (behaviour support only): Old provider keeps daily living; New 
provider receives Fade Plan + last review and begins coaching. Shared schedule 
avoids double-booking. Receipts split by activity codes; no service gap. 

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• Obstructed exit: Exit Pack late; governance issues Stage 1 notice. When keys aren’t 
returned, Stage 3 targeted payment hold applies to the old provider’s community-
access category; person’s week proceeds with new provider. 
• Medication clean-up: Entry provider’s 72-hour reconciliation finds duplicate 
psychotropics; prescriber contacted; PRN clarified; DPIA notes updated; family 
receives plain-language summary. 
 
Quick scripts 
• To the person/rep (start): 
“You can change providers. We’ll move your week, your supports and your 
information safely. Your services keep running while we settle the admin.” 
• Between providers (handover call): 
“We’re following the standard switch protocol. Exit Pack by Friday; Entry Pack 
stands up two weeks of schedule. Disputes go to governance - care continues.” 
• If old provider delays: 
“A late pack triggers a governance notice and, if needed, a payment hold on the 
categories at issue. Please send sections A-H today; integrity items can follow.” 
 
Privacy & security 
• Use pseudonym keys in the bundle; names in the secure directory. 
• Encrypt files at rest and in transit; share via approved link with expiry. 
• Remove precise addresses from any public-facing artefacts. 
• Log every access and change (Appendix T Audit Log Spec). 
 
Where to get help / Artefacts & Templates 
• Switch Notice & Consent Form 
• Exit/Entry Data Set  -  JSON/CSV schema + human-readable PDF pack 
• Two-Week Stand-Up Schedule (fillable) 
• Keys/Equipment Handback Checklist 
• Continuity & Escalation Flowchart 
• Governance Notification & Payment-Hold Notice (targeted) 
 
Summary companion. Decisions rely on the governing sections named in Choice & 
Control, Privacy/DPIA, Truth-by-Design and the Independent Verification & Integrity 
policies. 
 
 

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Appendix N  -  Interpreter/Auslan/AAC Toolkit 
Owner: Communication Access 
Interfaces: Choice & Control; Accessible Plan Pack (Appendix K); Handover & Medication 
Reconciliation (Appendix D); 72-Hour Learning Review & Fade Plan (Appendices B-C); 
Complaints & Appeals; Independent Verification; Privacy/DPIA; Workforce (IDC OSCEs); 
Health/ED interfaces. 
Why this matters (and why it hasn’t worked) 
People are too often asked to guess what’s being said - or to “nod along” - because 
interpreters aren’t booked, AAC isn’t set up, or family are used in place of professionals. 
That leads to unsafe consent, missed pain, avoidable restraint and complaints. This toolkit 
makes access the default: offer early, book properly, set up AAC, and record what was 
provided and how decisions were made. 
Fast take (read this first) 
• Always offer communication access for material decisions, health visits, 
investigations, reviews and complaints. 
• Use qualified interpreters (Auslan/spoken language), not family/friends or the support 
worker on shift. 
• Set up AAC every time: yes/no method, boards/device charged, vocabulary ready. 
• Record the method (who, language/mode, start/stop, NAATI/registration if relevant, 
offer/decline and why). 
• Urgent rule: if in doubt, tele-interpreting in ≤2 hours; in-person for planned events. 
• Never proceed with restrictive practices, consent or medication changes without an 
accessible explanation and a recorded method of agreement. 
• Measure it: fulfilment rate, time-to-fill, and “offer made/declined” are tracked on 
dashboards. 
Scope 
All settings (home, community, ED/health, day programs, police/tribunal touchpoints). 
Covers spoken-language interpreters, Auslan, Deaf interpreters (DI), and AAC (unaided and 
aided - yes/no, pictures, devices/apps, text-to-speech). 
 
When access is required (minimum triggers) 
• Consent for treatment/medication; behaviour support/restrictive-practice decisions. 
• Complaints, investigations, sanctions, tribunal preparation. 
• Assessments, plan reviews, switching providers, serious incident debriefs (72-hour 
reviews). 
• Any meeting where the person or family says they need help to understand or be 
understood. 
Offer/decline rule: Offer every time. If declined, record who declined and why, and ensure 
AAC scaffolds are still provided. 

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Roles & boundaries 
• Interpreter (spoken/Auslan/DI): impartial, interprets meaning accurately, manages 
turn-taking, keeps confidentiality. Not a support worker or advocate in the room. 
• Support worker/IDC: prepares the environment, ensures AAC is present, speaks 
plainly, and never “interprets” for the person. 
• Coordinator/Clinician: books the interpreter, chairs the meeting, checks 
understanding, documents access provided. 
• Family/Representative: supports preferences and checks that access was offered; 
should not act as the interpreter except in a true emergency, recorded as such. 
 
Booking rules (spoken language & Auslan) 
• Lead times: planned events ≥3 business days; investigations/ED via tele in ≤2 hours. 
• Type: Auslan → NAATI-certified Auslan interpreter; complex or DeafBlind → Deaf 
interpreter + Auslan interpreter pair. 
• Conflicts: avoid relatives/friends; ask the person about gender/cultural preferences. 
• Session length: ≥60 minutes book two interpreters for long/complex sessions. 
• Briefing: send topic, agenda, names/roles, and any jargon to avoid. 
• Privacy: interpreter signs confidentiality; no recording unless approved by DPIA. 
• Documentation: record provider/agency, interpreter ID/NAATI, start/stop times, and 
any issues. 
 
AAC essentials (set up every time) 
1. Yes/No method confirmed (gesture, card, nod, eye-blink) - write it down. 
2. Device/app ready: charged, unlocked, correct vocabulary page. 
3. Back-ups: paper core board, alphabet board, pen/paper. 
4. Environment: quiet space, face visible, one speaker at a time. 
5. Pacing: short sentences; check back (“Tell me in your way”). 
6. Recording: note what AAC was used and what the person expressed. 
Quick AAC set-up check (60 seconds) 
• “Show me how you say yes / no.” 
• “Do you want device / pictures / talk?” 
• “Is this page right?” (open vocabulary) 
• “Would you like someone with you?” (ally/advocate) 
 
Consent & comprehension check (use and record) 
• Ask for teach-back: “Can you tell me in your words/pictures what we decided?” 
• Use two non-leading options when appropriate. 
• Record mode (interpreter/Auslan/DI/AAC type), attestation 
(tap/PIN/biometric/verbal-witnessed/alt-comm) and timestamp. 

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• If comprehension remains doubtful → pause the decision and escalate for independent 
verification. 
 
Documentation (minimum fields to capture) 
• Was access offered? (Yes/No) Who accepted/declined? Why? 
• Language/modality (e.g., Dari, Auslan + DI, AAC-device/board). 
• Interpreter details (agency, NAATI number if relevant) and start/stop times. 
• AAC provided (device type/app; board name/version). 
• Setting (ED/home/tribunal etc.) and purpose. 
• Attestation mode for any decision made. 
• Barriers (noise, time pressure) and actions to fix for next time. 
 
What good looks like / Red flags 
Good: interpreter or DI booked when needed; AAC visible and used; yes/no method 
recorded; teach-back completed; consent captured in an accessible way; decision stands up on 
review. 
Red flags: “family translated” in serious matters; staff “interpreting” on the fly; device 
uncharged; no record of offer/decline; restraint or sedation used where access could have 
prevented escalation. 
 
Micro-scenarios (worked) 
• ED triage (urgent): Person arrives distressed; tele-Auslan connected in 12 minutes; 
yes/no card used for pain scale; short-acting sedative for imaging explained and 
attested; med reconciliation booked. 
• Plan review (scheduled): Dari interpreter booked; agenda sent; AAC pictures used to 
choose between two community roles; teach-back confirms choice; Easy Read update 
shared. 
• Complaint meeting (contested): DI + Auslan pair engaged; Contradiction Matrix used 
later; Plain-English Reasons issued with video summary in Auslan. 
• Police contact: Interpreter requested at first contact; support worker provides AAC 
board but does not interpret; rights explained; entry logged. 
 
Quick scripts 
• Offering access (plain): “We can book an interpreter or set up your device and 
pictures so this makes sense. What would you prefer?” 
• If someone says ‘no interpreter’: “That’s okay - can we still set up your device and 
yes/no cards? We can also get a phone interpreter anytime if you change your mind.” 
• To an interpreter (pre-brief): “Goal: agree a plan change. Please keep it literal, signal 
if pacing is too fast, and tell us if you need a break.” 
 
Measures & dashboards (track and improve) 

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• Offer documented (%) for eligible meetings. 
• Fulfilment rate (%) (interpreter/Auslan requests filled). 
• Time-to-fill (median minutes to interpreter on line/in room). 
• AAC present & used (%) in eligible meetings. 
• Event outcomes (e.g., restraint avoided; comprehension confirmed). 
• Complaints about access (count, resolved inside standard). 
 
Privacy, safety & ethics 
• Use secure booking channels; never share personal numbers. 
• Avoid using minors or family as interpreters except for immediate safety - record as 
emergency and replace ASAP. 
• For recordings (e.g., Auslan video explanations), complete a DPIA; store with access 
controls; share only with consent. 
• Respect cultural protocols (gender, kinship, community sensitivities). 
 
Where to get help / Artefacts & Templates 
• Interpreter/Auslan booking form & SLA sheet 
• AAC quick set-up card (yes/no, core words, troubleshooting) 
• Teach-back & consent checklist (attestation modes) 
• ED communication card (wallet/phone) 
• Session record form (offer/decline, interpreter IDs, start/stop) 
• Plain-language scripts (offer, decline, pre-brief, close-out) 
 
Summary companion. Decisions rely on the governing sections named in the 
Communication Access policy, Choice & Control Standard, Health Interface policies 
and Privacy/DPIA. 
 
Appendix O  -  First Nations Partnership MOU Template & Cultural Plan 
Owner: First Nations Partnerships & Community 
Interfaces: Choice & Control; Communication Access (Appendix N); Accessible Plan Pack 
(Appendix K); Weekly Community Schedule (Appendix L); Handover & Medication 
Reconciliation (Appendix D); Complaints & Appeals; Workforce/IDC; Procurement; 
Privacy/DPIA; Public Reporting. 
Why this matters (and why it hasn’t worked) 
Too many services “consult” late, rely on family as interpreters, and miss local protocols - so 
supports feel unsafe, participation drops, and trust erodes. A clear Partnership MOU with a 
practical Cultural Plan puts self-determination first: cultural authority is named, consent is 
accessible, data is handled respectfully, and Elders and local organisations are paid and 
involved. 

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Fast take (read this first) 
• Partner early with the local Aboriginal Community Controlled Organisation 
(ACCO) or recognised cultural authority. 
• Sign an MOU that sets roles, decision rights, data rules, payments, and dispute paths. 
• Make a Cultural Plan with the person/family that guides everyday practice (places, 
people, language, ceremony, Sorry Business, gender-specific care). 
• Pay for cultural work (brokerage, Elders’ time, interpreters). 
• Record consent for any information sharing with community bodies; follow data-
sovereignty principles. 
• Measure it: fulfilment of MOU actions, interpreter use, complaint resolution, and 
participation on Country. 
Scope 
All services supporting First Nations people across home, community, health, education, 
work and justice interfaces; applies to urban, regional and remote contexts. Use local 
Nation/Language names where the person prefers. 
 
Part 1  -  Partnership MOU (structure & clauses) 
A. Parties & purpose 
• Provider, the person/representative, and local ACCO / cultural authority. 
• Purpose: culturally safe, self-determined supports; clear roles; shared problem-
solving. 
B. Guiding principles 
Self-determination; cultural authority; free, prior & informed consent; trauma-aware practice; 
strengths-based; reciprocity; Indigenous data-sovereignty (collective benefit, authority to 
control, responsibility, ethics); privacy by design. 
C. Scope of collaboration 
• Planning & review meetings; crisis response; hospital/ED interfaces; complaints; 
recruitment & training; publication notes that concern culture; Switching Protocol 
support. 
D. Decision-making & cultural authority 
• Who can speak for what (Elders, nominated kin, ACCO role). 
• Men’s/Women’s business; Sorry Business protocols; who approves what, and how. 
E. Access & language 
• Interpreter/Auslan/AAC booking standards; preferred language(s); who pays; 
minimum lead times; emergency tele-interpreting. 
F. Workforce & capability 

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• Cultural capability requirements; induction on Country; shadowing ACCO staff; 
OSCE-style checks for cultural practice (greetings, introductions, protocol checks, 
consent scripts). 
G. Information sharing & data 
• What can be shared, with whom, and how consent is recorded; storage location; 
retention; community access rules; publication safeguards (no small-cell harms). 
H. Payment & procurement 
• Fees/honoraria for Elders and cultural brokers; preferred procurement from 
Aboriginal-owned businesses; travel costs. 
I. Dispute resolution & complaints 
• Culturally safe path; timelines; escalation to independent bodies; protection from 
retaliation. 
J. Reporting & review 
• Quarterly check-ins; measures (below); MOU renewal/termination clauses. 
K. Signatures 
• Provider exec; ACCO/cultural authority delegate; person/representative; date. 
 
Part 2  -  Cultural Plan (person-level, used day-to-day) 
1) Identity & connections 
Nation/Language group (if the person wishes to record), totems/skin names (optional), key 
kin and community ties, safe/not-safe places. 
2) Communication & language 
Preferred language(s); interpreter needs; plain-English phrases; AAC methods; who can 
speak for the person and when. 
3) Protocols & responsibilities 
Men’s/Women’s business preferences; Sorry Business arrangements; ceremony/seasonal 
obligations; who should (and should not) be present. 
4) On-Country preferences 
Important places; welcome/smoking ceremony options; what helps when away from Country. 
5) Health & practice notes 
Cultural considerations for touch, food, medicines, gender of clinician; how to introduce new 
workers; who to call first in worry. 

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6) Weekly rhythm & community roles 
Preferred community venues and events; named allies; transport; backup plans. 
7) Consent & data choices 
What can be shared with ACCO/authority; photos/video rules; publication preferences; 
renewal dates for consent. 
8) Safety & escalation 
Early signs of distress; words that work; who leads in crisis; how cultural authority is 
involved quickly. 
9) Review & sign-off 
Update after life changes; signatures/attestations (person/rep; ACCO; provider). 
 
How to build it (step-by-step) 
1. Invite the right people: person/rep + ACCO/cultural authority + key allies; book 
interpreter if needed. 
2. Walk Country or meet on Country if preferred; begin with introductions and 
protocols. 
3. Draft the Cultural Plan with the person; confirm consent choices for sharing. 
4. Complete and sign the MOU (or update if in place). 
5. Embed: add Cultural Plan pages to the Accessible Plan Pack (K); reflect in schedule 
(L), handover pack (D), and staff induction. 
6. Review quarterly or after major events (e.g., Sorry Business, moving house, health 
change). 
 
Who does what 
• Person/Representative: states preferences, approves sharing choices, names cultural 
authority. 
• ACCO/Cultural authority: guides protocols, provides brokers, co-chairs reviews on 
request, assists with complaints. 
• Provider Coordinator/IDC Lead: books interpreters, ensures plan is used, pays fees 
promptly, logs access provided. 
• Manager/Executive: signs MOU, funds cultural brokerage and training, tracks 
measures, responds to complaints. 
• Governance: ensures publication and data use respect cultural safety and suppression 
rules. 
 
What good looks like / Red flags 
Good: MOU signed; Cultural Plan in the person’s pack; interpreters used; Elders’ time paid; 
Sorry Business respected; participation on Country grows; complaints drop and resolve 
quickly. 
Red flags: “We asked family to translate”; no cultural authority named; rushed decisions 
without consent; refusal to pay for cultural work; publication that reveals small communities. 

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Measures (publish internally; some to dashboards) 
• MOU in place (yes/no); Cultural Plan current (yes/no). 
• Interpreter fulfilment rate; time-to-fill for urgent bookings. 
• % shifts led by culturally competent staff (OSCE in date). 
• Participation on Country (sessions/month; venues). 
• Complaints about cultural safety (count; resolved inside standard). 
• Spend with Aboriginal-owned suppliers (%). 
 
Micro-scenarios (worked) 
• ED visit: ACCO broker meets the person; tele-interpreter joined; male nurse 
requested and arranged; short procedure explained; consent confirmed via AAC; 
discharge includes clear plan and follow-up with ACCO. 
• Sorry Business: Two-week change to schedule; provider funds temporary travel; 
participation tracker pauses community roles respectfully; receipts continue for 
agreed supports; no cancellation penalties. 
• Complaint about a worker: ACCO co-chairs the meeting; Contradiction Matrix 
used; outcome letter in plain English with cultural plan updates; apology delivered 
and accepted. 
 
Quick scripts 
• Opening the partnership: “We work with the local community-controlled 
organisation so your supports follow the right protocols. Who should we speak with 
as cultural authority for you?” 
• Consent for sharing: “These pages say what we can share with the community 
organisation and what stays private. You can change this anytime.” 
• On payment: “We pay Elders and cultural brokers for their time. Here’s the rate and 
how we book.” 
 
Privacy & data-sovereignty notes 
• Record consent for sharing with ACCO/cultural authority (mode, scope, timestamp). 
• Use pseudonym keys in datasets; store names in secure directories. 
• Apply small-cell suppression in any public reporting; no maps that identify 
households. 
• Respect community requests to review public wording before publication. 
 
Where to get help / Artefacts & Templates 
• Partnership MOU template (fillable) 
• Cultural Plan  -  person-level (print + Easy Read) 
• Cultural Brokerage booking & payment form 
• Interpreter/Auslan request (First Nations languages) 

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• Cultural OSCE rubric (worker competence) 
• Sorry Business protocol & schedule change form 
• Data-sharing consent form (with revocation option) 
 
Summary companion. Decisions rely on the governing sections named in the First 
Nations Partnership commitments, Choice & Control, Communication Access, 
Procurement and Privacy/DPIA. 
 
Appendix P  -  Rural Micro-Hub Operating Pack & Tele-OSCE Protocol 
Owner: Rural & Remote Access + Workforce 
Interfaces: Workforce (IDC & OSCEs); Accessible Plan Pack; Weekly Community 
Schedule & Participation; Interpreter/Auslan/AAC; First Nations Partnership; Handover & 
Medication Reconciliation; E-Receipts & Cross-Checks; Governance & Complaints; 
Privacy/DPIA; Procurement. 
Why this matters (and why it hasn’t worked) 
In rural towns, long travel, thin rosters and last-minute cancellations shrink participation and 
stall workforce competence. Training is classroom-heavy, assessment is rare, and people wait 
months for help. Micro-hubs anchor services in local venues, and tele-OSCEs let us observe 
safety skills without shipping everyone to the city - so weeks are predictable, skills are 
verified, and travel becomes purposeful, not waste. 
Fast take (read this first) 
• Micro-hub = small, dependable base in a local venue (library, council hall, ACCO 
site), with privacy zones, connectivity, and a weekly timetable. 
• Run with a simple kit (connectivity + power backup + AAC + camera/mic + 
lockable storage) and clear emergency links to local health. 
• Publish an A/B timetable (weekday + weekend) so families know when the hub is 
live. 
• Tele-OSCE uses a standard room layout, two cameras, an onsite proctor, and a 
remote examiner; scenarios are timed and scored on a common rubric. 
• Accessibility by default: interpreters/Auslan/AAC offered; cultural protocol set with 
the local authority; venues and scripts in plain English. 
• Data & integrity: e-receipts for sessions, audit-logged OSCE results, privacy 
safeguards, and small-cell suppression in any publication. 
Scope 
Rural and remote communities (including pop-up outreach). Applies to day programs, skill-
building, plan reviews, coaching, and competency assessment (OSCE). Use with First 
Nations partners where relevant. Thresholds marked [POLICY] are set by the standards 
owner. 

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Part 1  -  Micro-Hub Operating Pack 
A) Site selection & agreements 
• Venue: accessible entry/amenities; two rooms (quiet room + shared space) or 
configurable screens; safe parking/lighting. 
• MOU: with local council/ACCO/school - hours, keys, costs, Wi-Fi, cleaning, 
insurance, emergency contacts. 
• Cultural plan: local protocols, Sorry Business arrangements, signage language. 
B) Minimum kit (fit in two road cases) 
• Connectivity: primary broadband (fixed/4G/5G/Starlink) + failover hotspot; router 
with QoS; SIM on rural carrier. 
• Power: UPS (≥[POLICY] minutes) for router/laptop; surge protection. 
• Audio/Video: 2 webcams (wide room + close face/hands), tripod, boundary mic or 
lapel mic, LED panel, headphones. 
• Computing: laptop with camera switcher or hub; locked-down OS; screen share. 
• AAC & access: yes/no cards, core boards, tablet with speech app, low-tech kits. 
• Privacy: portable screens, door sign system, lockable cabinet for records/gear. 
• Other: printer/scanner, labeler, basic first-aid kit. 
C) Operating rhythm 
• Timetable: publish weekly hours, drop-in times, and booked sessions (OSCE, 
coaching, plan reviews). 
• Booking & reminders: SMS/voice, interpreter/Auslan pre-booked, transport aligned. 
• Arrival flow: sign-in, quick access check (AAC present? interpreter?), e-receipt QR 
for the session. 
• Safety: incident kit; local ED/GP contacts; evacuation plan on wall. 
• Data trail: e-receipts for supports; audit log for any document transfer; no local 
storage beyond DPIA-approved cache. 
D) Privacy & DPIA guardrails 
• Hub DPIA approved before opening; no CCTV in private rooms; if entry CCTV 
exists, signage + retention set by venue. 
• Windows frosted or screened; sound bleed managed; paper notes minimised; 
everything else digital and access-controlled. 
• Small-cell suppression and coarse geography in any public reporting about the hub. 
E) Staffing & roles 
• Hub host (level 1): opens/sets up, greets, runs kit, knows the timetable. 
• IDC lead (level 2): runs sessions, completes e-receipts, leads de-escalation. 
• Proctor (OSCE days): identity checks, room setup, timing, integrity. 
• Cultural broker/ACCO link (as applicable). 
• Tech support (remote help-desk). 
 
Part 2  -  Tele-OSCE Protocol (Observed, structured competence) 

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Purpose: Verify that staff can do the safety-critical tasks they’re paid for, under observation, 
with accessibility and integrity. 
A) Roles 
• Candidate (worker). 
• Remote examiner (qualified assessor). 
• Onsite proctor (neutral, trained; manages room & integrity). 
• Standardised person/actor (onsite or remote, as the station requires). 
• Interpreter/Auslan or AAC support (if needed for fair access). 
• Tech support (on call). 
B) Environment & tech 
• Room layout: 3 m x 3 m clear space; desk; chair; door visible in wide camera. 
• Cameras: 
o Cam 1 = wide shot (candidate + space). 
o Cam 2 = close shot (hands/faces/materials). 
• Audio: boundary mic or lapel; speakers off or echo-canceled. 
• Connectivity: stable link ≥ [POLICY bandwidth] up/down; latency ≤ [POLICY 
ms]. 
• Lighting: face lit; no backlight glare. 
• Privacy: door sign “Assessment in progress”; no bystanders. 
C) Integrity & identity 
• Candidate shows photo ID; proctor pans room with Cam 1 before start. 
• Phones/watches on a side table; only permitted materials in reach. 
• All events time-stamped; examiner and proctor complete a short integrity checklist. 
• Recording only if approved by DPIA; if recorded, hash stored with the scoring file. 
D) Accessibility & fairness 
• Interpreters/Auslan allowed; non-leading role briefed by examiner. 
• AAC supported; extra time [POLICY] when access requires; content unchanged. 
• Practice orientation (5-10 min) before first OSCE; sample prompts provided. 
E) Station design & scoring 
• Each OSCE = scenario + tasks + critical-fail items + rubric. 
• Timing: 8-12 min per station + 3 min changeover (or per [POLICY]). 
• Score: pass/fail per critical item; overall Pass if all criticals met and total ≥ [POLICY 
%]. 
• Examples: 
o De-escalation & least-restrictive decision (words + timing start/stop). 
o Safe handover & med reconciliation mock. 
o Communication access setup (yes/no + AAC + interpreter brief). 
o Incident log with start/stop and 72-hour review booking. 
F) Flow (candidate view) 

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1. Check-in & ID → access needs confirmed. 
2. Orientation & tech check (2-3 min). 
3. Station 1 → changeover → Station 2 → … 
4. De-brief (2-3 min): high-level feedback; results later the same day. 
5. Result email + actions (coaching/retake plan) filed to the record. 
G) Failures, retakes & appeals 
• Critical fail → overall fail for that OSCE; remediation plan with coaching; retake 
window [POLICY days]. 
• Appeal path uses Reasons & Weighting with an independent second marker; 
summary shared with the worker. 
H) Data, storage & publication 
• Store scores + rubric + integrity checklist + examiner notes; keep video only if 
DPIA allows and retention is set. 
• Publish counts/percentages of currency by provider (Workforce tile), not individual 
names. 
 
Measures (monitor monthly; some publish) 
• Hub open hours delivered vs planned (%). 
• Session cancellations (rate) and reasons. 
• Interpreter/AAC fulfilment (%). 
• Tele-OSCE completion & pass rate; currency of required OSCEs (% in date). 
• Time-to-assessment (days from booking). 
• Participation: sessions out-of-home/week; variety index. 
• Travel saved (km or hours) vs previous model. 
• Complaints about access or cultural safety (count; resolved inside standard). 
 
What good looks like / Red flags 
Good: predictable timetable; gear always works; interpreters show up; people know when the 
hub is open; OSCEs run on time; feedback leads to coaching; participation rises and 
cancellations fall. 
Red flags: pop-up only when inspectors visit; single camera; no privacy screens; recordings 
without DPIA; access not offered; long waits for assessment; staff practising unsafe tasks 
while “awaiting OSCE”. 
 
Micro-scenarios (worked) 
• Storm day: Primary link drops; hub fails over to satellite; examiner pauses 60 
seconds; OSCE resumes; integrity checklist notes the switchover. 
• First Nations partnership: ACCO lounge used as hub 2 days/week; MOU covers 
keys/hours/payments; cultural broker co-chairs plan reviews; participation on Country 
increases. 

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• Audio failure mid-station: Proctor switches to lapel mic; station time extended by 
[POLICY] for fairness; event logged; candidate passes. 
• New worker remediation: Fails “least-restrictive” critical; receives coaching; retakes 
in 10 days; passes; roster unlocks scope. 
 
Quick scripts 
• To the community: “This hub gives you a local base - clear hours, interpreters when 
needed, and the gear to do video assessments so staff don’t have to leave town.” 
• To a candidate: “We’re observing real skills. Two cameras, one proctor, one remote 
examiner. If tech hiccups happen, we pause and log it - fairness first.” 
 
Where to get help / Artefacts & Templates 
• Micro-hub site & MOU checklist 
• Hub DPIA & privacy signage set 
• Kit list & setup guide (network, power, cameras, AAC) 
• Weekly timetable poster + SMS reminder scripts 
• Tele-OSCE proctor checklist & integrity form 
• OSCE station packs & scoring rubrics (de-escalation; med recon; communication 
access; incident logging) 
• Result letter + remediation/retake plan 
 
Summary companion. Decisions rely on the governing sections named in 
Workforce/IDC, Communication Access, First Nations Partnership, Health Interface 
policies and Privacy/DPIA. 
 
Appendix Q  -  IDC Curriculum Map, EPA Logbook & OSCE Rubrics 
Owner: Workforce (IDC) 
Interfaces: Safety & Restrictive Practices; Handover & Medication Reconciliation; 
Communication Access; Participation/CPI; E-Receipts & Cross-Checks; Independent 
Verification (R&W, Contradiction Matrix, IRC); Governance & Complaints; Privacy/DPIA. 
Why this matters (and why it hasn’t worked) 
People are safest when workers are observed-competent, not just “trained”. Today, courses 
are tick-box, scopes drift, and there’s no shared proof of who can do what. This appendix sets 
a single pathway: what IDC staff learn (Curriculum Map), what they may be entrusted to do 
(EPAs with a logbook), and how they are observed doing it (OSCE rubrics)  -  with clear 
renewal and audit. 
Fast take (read this first) 

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• Scope = competence = scope of practice. You may only do tasks you hold current 
EPA level for (L3-L5). 
• Curriculum Map shows modules and outcomes; EPAs are the real licence 
(entrustable tasks in the field). 
• OSCEs test the safety-critical core; logbook proves real-world practice. 
• Currency expires unless renewed (see rules). 
• Integrity by design: audits, hashed results, and publication as workforce tiles (no 
names). 
Scope 
All IDC roles (entry, advanced, lead). Applies in home, community, day programs, short-
stay, health interfaces and rural micro-hubs. 
 
IDC Curriculum Map (what we teach, how it builds) 
This appendix defines the whole teaching-and-testing spine for the Integrated Disability 
Clinician (IDC) pathway and the Community Ally baseline (parents, guardians, volunteers). 
It maps learning modules, supervised practice, EPAs, OSCEs, logbook headers, renewal 
rules, and calibration. 
Bands. IDC-Associate → IDC-Full → IDC-Advanced (educator/supervisor). 
Supervised practice (IDC). 360-450 hours blended across settings (recommended anchors: 
270-300 h hospital placements; 250-300 h disability/community; 100 h community clinic). 
Hours may be achieved via pilots/micro-hubs/tele-OSCE blend with named supervision. 
Safety stations (mealtime/IDDSI, seizure response, medication handover, least-restrictive 
practice, AAC-in-conversation, documentation integrity) are never waived; RPL may 
shorten pathways but cannot remove these safety gates. 
 
Q-1 Curriculum Map (M1-M19) 
How to read: each module lists outcomes, indicative learning/practice, and assessment 
hooks. 
M1. Rights, Law & Duty of Care 
Outcomes: supported decision-making in practice; consent; privacy by design; least-
restrictive tests. 
Learn/practise: case huddles; reasons-in-plain-English drill. 
Assess: short viva; R&W micro-table; conflict scenario. 
M2. Service Models & Practice Theory 
Outcomes: role clarity; outcome focus; boundaries. 
Assess: supervision observation (boundary cueing; rescue-to-coaching swap). 
M3. Communication & AAC Basics 
Outcomes: functional profiling; quick AAC set-ups; plain notes. 
Assess: OSCE station “AAC in conversation”. 

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M4. Community Access & Participation 
Outcomes: CPI timetable; role-building; graded exposure. 
Assess: EPA-2 “Run a community session”. 
M5. PBS Foundations 
Outcomes: ABC data; function hypotheses; non-aversive strategies; fidelity. 
Assess: mini-plan with three graduated alternatives. 
M6. Mealtime & Dysphagia Safety (IDDSI) 
Outcomes: textures/fluids; positioning; red flags. 
Assess: OSCE station “Mealtime safety” + field observation. 
M7. Epilepsy & Seizure Response 
Outcomes: recognition; rescue-med delegation where permitted; escalation. 
Assess: OSCE station; logbook capture of one supervised response drill. 
M8. Medication Safety & Psychotropic Stewardship 
Outcomes: six rights; side-effect watch-list; reconciliation; PRN rules. 
Assess: OSCE “Handover & reconciliation”. 
M9. Health in Daily Living 
Outcomes: infection prevention; skin/continence; diabetes/bowel basics; sleep hygiene; 
manual handling. 
Assess: checklist + supervisor sign-off. 
M10. Human Development & Disability 
Outcomes: lifespan and sensory processing implications. 
Assess: short case mapping to supports. 
M11. Assessment → Planning → Review 
Outcomes: intake; goal setting; outcomes/measure link; review cadence. 
Assess: plan extract aligned to dashboard fields. 
M12. Casework, Records & Evidence 
Outcomes: contemporaneous notes; chronology; evidence chains; document control. 
Assess: documentation integrity rubric. 
M13. Cultural Safety & Family Partnership 
Outcomes: First Nations partnership; CALD/Auslan access; sexuality/relationships & 
consent. 
Assess: interpreter booking & pre-brief flow; reflective note. 
M14. Community Systems & Navigation 
Outcomes: health/education/housing/justice interfaces; referrals; case conferences; advocates’ 
roles. 
Assess: handover packet assembly (Appendix D links). 
M15. Safeguarding & Restrictive-Practice Governance 
Outcomes: restraint hierarchy; timekeeping; 72-hour review; fade plans. 
Assess: OSCE “De-escalate & document” + 72-hour review write-up. 

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M16. Assistive Tech & Digital Practice 
Outcomes: AT basics; accessibility settings; privacy; safe photos/video. 
Assess: DPIA mini + AT deployment checklist. 
M17. Quality Improvement & Outcomes 
Outcomes: PDSA; tile literacy; preparing for audit. 
Assess: one PDSA cycle with baseline → change → result. 
M18. Practice Education (Supervised Placements) 
Outcomes: block practicums; observed EPAs; portfolio build. 
Assess: EPAs 1-5 completions; supervision notes. 
M19. Leadership & Supervision (advanced) 
Outcomes: reflective practice; coaching; safe rostering; investigation basics; service 
readiness. 
Assess: observed supervision conversation + risk review. 
 
 
Q-2 EPA Logbook (headers and rules) 
Logbook headers (CSV-friendly): 
date, setting (home/community/clinic/hospital/justice), module tag (M1-M19), EPA code 
(EPA-1…EPA-5), scenario summary (≤140 chars), observer role/name, supervision level 
(direct/indirect), outcome (pass/coach/remediate), follow-ups due (date), file-vs-field 
alignment (yes/no), privacy note (if any), candidate signature, supervisor signature. 
EPAs (Entrustable Professional Activities): 
• EPA-1 Plan conversation with SDM & accessible materials (M1,M3,M11). 
• EPA-2 Deliver a community session that builds presence (M4). 
• EPA-3 Manage low-to-moderate escalation using least-restrictive options; start 
timekeeping if restraint occurs; trigger 72-hour review (M5,M15). 
• EPA-4 Complete a safe medication handover/reconciliation (M8,M9,M14). 
• EPA-5 Produce a clean documentation pack incl. two-party e-receipt where 
applicable (M12,M17). 
Completion rule. Each EPA is observed twice without critical error, at least one by an 
external supervisor. Safety EPAs can’t be RPL-waived. 
 
Q-3 OSCE Blueprint & Rubrics (summary) 
Circuit design (6-8 stations): 
1. Person-first planning & consent (M1,M11) 
2. AAC in conversation (M3) 
3. Community role-building (M4) 
4. De-escalate & rights test + 72-hour review stub (M5,M15) 
5. Mealtime/IDDSI safety (M6) 

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6. Seizure response (M7) 
7. Medication handover & reconciliation (M8,M14) 
8. Documentation integrity & privacy (M12,M16,M17) 
Scale: 0 Unsafe · 1 Needs improvement · 2 Competent · 3 Exemplary. 
Pass: all bolded safety criteria ≥2; overall mean ≥2.0. 
Calibration: double-rating on sample videos; kappa published; annual standard-setting. 
(Rubrics mirror the rOSCE style you approved  -  if you want, I can drop the full per-
criterion wordings into this appendix verbatim.) 
 
Q-4 Supervised Practice Hours & Bands 
• IDC-Associate: 360-380 h blended; at least 2 safety OSCE stations sat during 
programme; 10 field observations; 2 external. 
• IDC-Full: 400-420 h; full OSCE circuit sat; 12 observations; 2 external; two EPAs at 
“exemplar” once. 
• IDC-Advanced: 430-450 h; mini-educator module; examines at least one OSCE 
sitting; leads two supervisions documented. 
Setting anchors (target ranges during total hours): 
• Hospital placements 270-300 h (acute, ED liaison, GP handover interface). 
• Disability/community 250-300 h (home, community roles, participation). 
• Community clinic ~100 h (micro-hub/tele-OSCE prep, allied health liaison). 
 
Q-5 Renewal & Currency 
• Cycle: 3-year renewal; 40 hours CPD/year (≥8 hours equity). 
• Mini-OSCE: 3 stations (one safety) or equivalent workplace assessment; two fresh 
field observations; documentation candour check. 
• Recency: ≥600 h frontline practise across cycle (or supervised equivalent). 
 
Q-6 Community Allies Baseline (parents/guardians/volunteers) 
Why this exists. Being a parent, guardian or volunteer does not automatically imbue the 
knowledge or habits needed for safe, growth-oriented support. Many well-intentioned efforts 
have missed the mark, leaving the person at centre to unlearn what didn’t help. Good 
intentions need current practice, shared language with clinicians, and a habit of learning in 
community (not alone). 
Scope (non-clinical). Conversations, companionship, graded practice in ordinary places, 
low-arousal basics, safe transport, privacy habits, brief plain-English notelets to the IDC. 
Clinical decisions remain with the IDC/clinician. 
Learning commitment (light but real). 

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• Micro-credential: 8-12 hours short course + 6-10 hours coached practice. 
• Keep current: attend a local/network session at least twice a year 
(PBS/mealtime/AAC update or community forum). 
• Read & refresh: skim the “What Can Go Wrong (Even With Love)” guide every 6 
months; add one new practical strategy to the weekly plan. 
• Co-reflect: after two community sessions, share one success and one stuck point 
with the IDC; agree the next micro-skill. 
Assessment (supportive, not high-stakes). 
• Short scenario viva (plain-language). 
• “What Can Go Wrong (Even With Love)” safety quiz. 
• Two coached community sessions with a reflection notelet. 
Network & trend habits (stay connected). 
• Join a local ally circle or online group curated by the service; swap ideas that worked 
(and those that didn’t). 
• Follow changes in IDDSI/mealtime, PBS, and AAC basics via the service’s quarterly 
digest. 
• Ask for an IDC show-me when something is new (e.g., a communication device, 
travel route, or community role). 
Safety absolutes (never DIY). 
• No changes to mealtime textures/positioning, medications, seizure plans, or 
restraint decisions. 
• If unsure, pause and ask. Record what you tried and what happened; the IDC decides 
next steps. 
Boundaries that protect everyone. 
• Money, PINs, and personal data only as the plan allows. 
• Photos/stories only with consent and for a clear purpose. 
• Home is not a workplace: keep support purposeful, time-bound, and scheduled. 
Interface with the IDC. 
• Use the weekly plan, not ad-hoc help. 
• Send short notelets (what we did, what helped, what didn’t). 
• IDC owns clinical records and decisions; allies are partners in practice, not 
substitute clinicians. 
 
Q-7 Data & Publication Hooks 
• Logbook and OSCE feeds map cleanly to dashboard tiles (licence/renewal rates; 
OSCE pass; supervision throughput). 
• Privacy & suppression rules apply on public tiles; family view shows person-level 
detail with role-based access (see Data, Dashboards & Privacy section in Draft 2).  

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What good looks like / Red flags 
Good: everyone knows their EPAs and levels; logbooks are current; OSCEs in date; fewer 
incidents; faster handovers; families see safe practice. 
Red flags: “trained” but never observed; expired OSCEs; vague logbook entries; scope 
creep; governance overrides without evidence. 
 
Micro-scenarios (worked) 
• New starter: Completes modules → shadows (L1-L2) → passes OSCE-C and 
OSCE-S → gains L4 on EPA-C1/EPA-S1 → logs 3 entries each in 3 months. 
• Drift caught early: Two E3 exceptions plus one poor de-escalation → manager sets 
coaching; tele-OSCE retake in 10 days; L4 restored after pass. 
• Equivalency: Experienced worker claims prior learning; passes OSCEs and submits 6 
months of verified EPA entries → mapped to IDC-Lead for EPA-R1 and EPA-H1. 
 
Quick scripts 
• To a worker: “Your scope equals your current EPAs. Keep your logbook live and 
your OSCEs in date - otherwise the system will limit what you can do.” 
• To a family: “Everyone who supports you is observed doing the safety-critical parts 
of their job. You can ask what EPAs your team holds.” 
 
Where to get help / Artefacts & Templates 
• Curriculum Map poster + module outcomes 
• EPA Logbook (fillable + CSV headers) 
• Supervisor/Verifier guide 
• OSCE station packs & rubrics (S, C, H, R, F…) 
• Progression & currency checklist 
• Scope change & remediation form 
• Audit & publication checklist (hashing, suppression) 
 
Summary companion. Decisions rely on the governing sections named in 
Workforce/IDC standards, Safety & Restrictive Practices, Communication Access, 
Health Interface policies and Privacy/DPIA. 
 
 
 

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Appendix R  -  Privacy, DPIA & Feed Registry 
Protect people’s rights while letting the system learn and improve. 
Owner: Privacy/DPIA Lead (with Data & Integrity; Legal; First Nations Partnership) 
Interfaces: Publication & Tiles (Appx S/AL); Audit Log (Appx T); E-Receipts (Appx E); 
Roster↔Claim (Appx F); Reasons & Weighting / Matrix / IRC (Appx H/I/J); Two-Key 
Register (IPP); Navigator/Foundational registry; DSC Audits (AG.1); Psychotropic 
Stewardship (AB); Mealtime/IDDSI (Z); Owner Matrix & Escalation (Y). 
 
Why this matters (and why it hasn’t worked) 
People with cognitive disability carry the heaviest privacy risks while receiving the most 
fragmented support. Historic reporting mixed person-level details into public artefacts, used 
shifting denominators, and leaked small cells. This appendix makes privacy operational: one 
DPIA method, a feed registry with minimum fields, small-cell suppression by default, and 
auditable provenance hashes. 
 
Fast take (read this first) 
• One DPIA per product/flow, registered and versioned; no feed goes live without it. 
• Minimum data always: collect only what is needed for the declared purpose. 
• Small-cell suppression and differencing guard on every published tile (Appx 
S/AL). 
• Provenance hash + role-based access for each dataset version (Appx T). 
• First Nations and CALD/Auslan checks on method and wording. 
• Switch-ready: when a person changes provider, their artefacts travel - not their raw 
histories. 
 
Scope 
All system components that process personal or sensitive information: intake, support 
delivery, incident/review, decision-making, integrity, publication, audit/assurance. Applies to 
providers, regulators, tribunals/OPA, Navigators, Plan Managers, and DSC actors where 
adopted. 
 
A. DPIA method (concise) 
1. Describe the purpose and lawful basis (consent, duty of care, public task, law). 
2. Map the data flow (collection → storage → use → share → publish/retain/destroy). 
3. Identify risks (re-identification, unfairness, chilling effect, safety). 
4. Controls (minimisation, access, encryption, suppression, noise, redaction, retention). 
5. Equity lens (First Nations partnership; interpreters/Auslan; Easy Read). 
6. Outcome & sign-off (accept, reduce, redesign; owner and review date). 
7. Provenance (dataset IDs, schema version, hash; change-log “S-8” note if public 
definition moves). 

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Cadence: initial DPIA, then review on any change to purpose, fields, recipients, algorithms, 
or publish rules. 
 
B. Feed Registry (what flows, who sees it, why) 
(Register each feed before go-live; paste these rows into the feed table. “PII fields” shows 
minimum set.) 
Feed ID Purpose 
(why) 
Source 
system(s) 
PII fields 
(minimum) Derived fields Role access Retention Lawful 
basis 
Publish
? 
R-E01 
e_receipts_
core 
Verify 
service 
occurred; 
person view 
of history; 
integrity 
E-Receipts 
app 
participant_id 
(pseudo), 
worker_id 
(pseudo), 
attestation 
markers, 
timestamps 
minutes, CPI 
flags, match 
status 
Worker (own), 
Person/Rep, 
Integrity, 
Navigator 
(read) 
7 yrs 
(statute) 
contract/p
ublic task 
No 
(aggrega
ted 
only) 
R-F01 
roster_clai
m_xcheck 
Detect 
billing 
exceptions 
Roster, 
Claims, E-
Receipts 
provider_id, 
shift_id (pseudo) 
match_rate, 
anomalies 
Integrity, 
Regulator 
(summary) 
7 yrs public task 
Tiles 
only (S-
Q11) 
R-H01 
reasons_ma
trix_bundle 
Appeal-
ready 
decisions 
R&W/Mat
rix/IRC 
store 
case_ref (pseudo), 
dates, role IDs 
(pseudo) 
weights table, 
contradictions 
Decision-
makers, 
DSC/Tribunal/
OPA 
per statute legal 
obligation 
No 
(digest 
only) 
R-K01 
twokey_reg
ister 
Show 
independenc
e & 
timestamps 
IPP/Two-
Key 
case_ref (pseudo), 
key_ids (pseudo) 
coverage %, 
time_to_secon
d_key 
Registry, 
DSC, Tribunal 7 yrs legal 
obligation 
Tiles (S-
P01/S-
Q07) 
R-N01 
navigator_
handover 
Continuity 
of support 
Navigator 
registry, 
E-Receipt 
(handover 
flag) 
case_ref (pseudo), 
handover artefact 
id 
warm_handov
er_rate 
Navigator, 
Person/Rep; 
DSC summary 
2 yrs consent/pu
blic task 
Tiles (S-
Q06; 
Family 
view 
detail) 
R-S01 
safety_revi
ews 
72-hour 
learning 
loop 
Incident 
log, 
Review 
notes 
case_ref (pseudo), 
event_time, 
reviewer_id 
(pseudo) 
review_on_tim
e %, 
restraint_min_
per_1000h 
Clinical Gov., 
DSC 7 yrs duty of 
care 
Tiles 
(Safety 
bundle) 
R-Q01 
osce_licensi
ng 
Workforce 
competence 
currency 
OSCE/EP
A registry 
worker_id 
(pseudo), station 
ids 
osce_currency 
%, 
licensed_scope
_coverage 
Workforce 
Licensing; 
DSC 
(summary) 
7 yrs employme
nt 
Tiles (S-
Q03/S-
Q04) 
R-AL01 
publication
_release 
Public 
accountabilit
y 
Tile 
engine none (aggregated) 
trend, notes, 
definition_vers
ion 
Public; 
Family; 
Provider 
evergreen 
(versioned) public task 
Yes 
(Appx 
S/AL) 
R-T01 
audit_log 
Provenance 
& trace 
Audit 
system 
event_id, actor_id 
(pseudo) 
hash_chain, 
change_type 
Privacy/Legal; 
DSC (subset) 7 yrs legal 
obligation No 
Rules: 
• Pseudonymous IDs by default; separate key vault for identity linkage. 
• Any new field/recipient = DPIA update and feed-table change. 
• Sharing with Ombudsman/Tribunal/DSC uses the same numbered evidence set 
(Appx H/I/J), not reconstructions. 
 
 

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C. Publication & small-cell discipline (for Appx S/AL) 
• Suppression: hide counts <5 and any rate derived from <5 events; show “Insufficient 
data”. 
• Differencing guard: introduce ±1-2% jitter or banding where repeated releases could 
reveal small cells by subtraction. 
• Coarse geography only (no addresses); time windows ≥28 days for public series. 
• Notes must be plain English; link to method and definition_version. 
• Family view: full personal history to the person/rep; never public. 
 
D. Role-based access & least privilege 
• Access profiles: Person/Rep; Worker (own records); Navigator (read); Provider 
Governance; Regulator/DSC; Tribunal/OPA; Data & Integrity; Privacy Lead. 
• Multi-factor auth for any dataset with health or restraint markers. 
• Break-glass with auto-notice to Privacy Lead + person/rep (where safe) for 
emergency reads. 
 
E. Rights, notices, and corrections 
• Right to access (person/rep): “My Visits” + copy of evidence relied on. 
• Right to correction: e-receipt correction flow with dual attestation; change-log 
preserved (no hard deletes). 
• Right to explanation: plain-language reasons (Appx H/J). 
• First Nations & language access: interpreter/Auslan/translation on request; record 
modality on each form (A-templates, AG-1A). 
 
F. Retention & destruction 
• Retain per statute (usually 7 years); hash manifest persists for public releases. 
• Secure destruction after retention ends; preserve audit hash and non-PII counts for 
research comparability. 
 
G. Breach & incident response (72-hour clock) 
1. Detect & contain (isolate dataset, revoke tokens). 
2. Assess risk (who, what, how many, likelihood of harm). 
3. Notify: Privacy Lead → leadership; regulator and affected people as required; 
provide clear next steps. 
4. Remediate: patch, rotate keys, retrain; publish S-8 change note if definitions or 
access rules shift. 
5. Learn: 72-hour review (Appx B/C); update DPIA and feed registry. 
 
 
 

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H. Algorithmic & metric fairness (where tiles or triage use scoring) 
• Register any scoring/thresholds (inputs, purpose, owner, drift monitors). 
• No person-level in public; only aggregates with suppression and trend bands. 
• Bias checks: stratify by First Nations, CALD, Auslan, gender, age band, rural/metro 
(publish only if cells ≥5). 
• Appeal route: decisions explain inputs and allow challenge (H/J; AG). 
 
I. Privacy hooks in core artefacts (tie-backs) 
• A-templates carry a Privacy Notice and translation options (A11, A12). 
• R&W/IRC require small-cell check boxes and a publication note. 
• Two-party e-receipt fields include interpreter_used, AAC_used, and 
notes_redacted. 
• Appendix S/AL tiles must embed owner_role, source_refs, definition_version, 
provenance_hash, suppressed. 
 
J. What good looks like / Red flags 
Good: each feed has a DPIA; minimum fields; pseudonymous IDs; small-cell guard; public 
tiles reproducible; provenance hash present; First-Nations wording reviewed; switch-ready 
exports work. 
Red flags: ad-hoc extracts; person-level data in public; changed denominators without an S-8 
note; unsuppressed tiny numbers; undefined lawful basis; live access granted outside roles. 
 
K. Micro-scenarios (worked) 
• Tile back-calc risk: Provider wants suburb tiles; cells <5. Outcome: publish 
provider-level only, add differencing guard; S-8 note explains comparability. 
• Navigator packet: Handover artefact includes phone number; DPIA trims to first 
name initial + role; full contact in private channel only. 
• Tribunal bundle: Member asks for full notes; provide numbered evidence with 
redactions; publish digest with suppression; record hash in Appx T. 
 
L. Artefacts & templates 
• R-FR1 Feed Registry (CSV)  -  one row per feed (fields above) 
• R-DPIA form (short/long)  -  with equity and publication sections 
• R-SR1 Small-cell decision tree  -  with examples 
• R-CH1 Change-log “S-8” note  -  public definition changes 
• R-AK1 Access profiles matrix  -  roles → permissions → expiry 
• R-BR1 Breach workbook  -  72-hour response and notices 
 

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Summary companion. Privacy is not a banner - it’s a build rule. Register the feed, minimise 
fields, suppress small cells, hash the bundle, and speak plainly. Everything else in the White 
Paper (Two-Key, R&W/Matrix, e-receipts, tiles) plugs into that spine. 
 
 
 
Appendix S  -  Dashboard Tiles, Suppression & Publication 
Owner: Lead Agency Analytics Unit 
Operational owners: Registry/OPA/NDIA Data Stewards (per tile) 
Interfaces: Two-Key Register; R&W store (H/J); DSC Audits; e-Receipt store (E); Audit 
Log (T); Licensing/OSCE (Q); Navigator/Foundational registries; Publication service (AL) 
Version: S-1.4.0 · Next review due: 30 days from publication 
 
Why this matters (and why it hasn’t worked) 
Without standard tiles, reporting slides into narrative, exceptions stay invisible, and 
publication lags. Dashboards do not mix incomparable denominators, there are no weak 
privacy controls, and hash-verifiable provenance exist. This appendix: demonstrates shared 
computation rules, suppression by design, and visible change-logs tied to the audit log (T). 
 
Fast take (read this first) 
• Six public tiles (S-P01…S-P06) show safety, reasons, integrity, and access. 
• Eleven internal QA tiles (S-Q01…S-Q11) drive market quality and enforcement. 
• Every payload ships with: source, period, last_updated, definition_version, 
population, suppression_applied, hash. 
• Small-number suppression (<5), role-based access, and DPIA hooks are mandatory. 
• Publish quarterly; refresh internal QA monthly; keep a visible change-log (S-8). 
 
Scope 
Applies to any published or internal performance tile referenced anywhere in this paper, 
including NDIS Interface, DSC calibration, IDC/COORD licensing, Foundational Supports, 
and sanction ladders. 
Formats: CSV + JSON (mandatory), API optional. Rounding: 1 decimal unless stated. 
 
S-Tiles at a glance: catalogue (required set) 
Public tiles (publish de-identified by region/provider-family) 
• S-P01 two_key_coverage  -  % consequential decisions with Two-Key recorded. 
• S-P02 restraint_minutes_per_1000hrs  -  restraint minutes per 1,000 support hours 
(by hierarchy internally). 

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• S-P03 r2r_on_time_rate  -  Right-to-Reasons delivered within service guarantees 
(%). 
• S-P04 navigator_coverage_rate  -  eligible participants with Navigator assigned or 
warm handover complete (%). 
• S-P05 foundational_access_time  -  median days referral → first attended 
foundational support (P50 & P90). 
• S-P06 doc_integrity_score  -  documentation integrity index (0-100). 
Internal QA & market-quality tiles (publish only in aggregate) 
• S-Q01 72h_review_completion_rate  -  % Tier-0/1 events with learning review 
≤72h. 
• S-Q02 dsc_file_field_concordance  -  % sampled items where field observation 
matches the file. 
• S-Q03 licensed_scope_coverage  -  % safety-critical tasks performed by OSCE-
licensed staff. 
• S-Q04 osce_pass_rate_coord_ops  -  OSCE/EPA pass rate for COORD/OPS licence 
classes. 
• S-Q05 coord_independence_rate  -  % COORD cases with no financial/managerial 
conflict. 
• S-Q06 navigator_warm_handover_rate  -  % COORD cases with e-receipted warm 
handover (where applicable). 
• S-Q07 time_to_second_key  -  median hours to valid second key on consequential 
decisions. 
• S-Q08 ops_gateway_elapsed_days  -  median days intake → first attended support 
(OPS roles). 
• S-Q09 mandatory_registration_uptake_sc_sil_platform  -  % in-scope providers 
transitioned to new class. 
• S-Q10 e_receipt_coverage  -  % delivered supports with dual attestation captured. 
• S-Q11 roster_claim_anomaly_rate  -  % shifts with unresolved roster↔claim 
discrepancies. 
 
Payload requirements (all tiles) 
Each record must include: 
tile, period, value, value_pct (if relevant), numerator, denominator, source, last_updated 
(ISO), definition_version (semver), population, suppression_applied (Y/N), 
suppression_rule_id, cell_count_min, extraction_ts, hash (Appendix T), contact_owner, 
notes. 
Provenance: Hash with Appendix T; no hard deletes; changes appear in the S-8 change-log. 
 
Definitions & computation rules (normative) 
• Consequential decision (Two-Key domain): acts affecting liberty, residence, 
psychotropic/chemical restraint, restrictive-practice authorisation/renewal, high-value 
AT/service changes, justice/hospital discharge to new setting. 

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• Valid second key: IPP independence screen passed; conflicts declared; identity 
verified; R&W note attached; pairing timestamps recorded. 
• On-time reasons: per jurisdictional guarantee; clock starts at decision notification. 
• Warm handover: (i) handover artefact present, (ii) person/family contact recorded, 
(iii) first appointment booked/kept  -  all three required. 
• Documentation integrity score (S-P06): 40% e-receipt coverage; 25% author 
identity/time-stamp concordance; 20% contradictions resolved (I); 15% audit-log 
completeness (T). Weights versioned. 
 
Privacy, suppression & redaction 
• Cell-size rule: suppress n < 5 or where cross-tab could identify a person/location (k-
anonymity ≥5). 
• Aggregation: public tiles at Quarter × Region/Provider-family; finer cuts restricted 
under role-based access. 
• Differencing guard: apply ±1-2% noise to small denominators; lock annual totals. 
• Redaction: code free-text reasons; band rare categories (<1%). 
• Consent & DPIA: person-level stories require consent; DPIA version noted in 
payload. 
• Small-cell suppression. Suppress any cell with n < 5 or where cross-tabbing could 
re-identify an individual (k-anonymity ≥ 5). Apply banding or aggregation as needed; 
for residual disclosure risk, add ±1-2% random noise and lock annual totals. 
 
 
Data-quality SLAs & validation 
• Timeliness: extract ≤15 days after period close; publish ≤30 days. 
• Completeness: mandatory fields present in ≥98% of records; e-receipt coverage 
target ≥85% in Y1 → ≥95% by Y3. 
• Concordance: DSC file-vs-field ≥90% (green) / 80-89% (amber) / <80% (red → 
calibration). 
• Reproducibility: computation notebooks and definition files versioned; reruns must 
reproduce values ±0.1. 
 
Roles, cadence & escalation 
• Data Owner: Lead Agency Analytics; Ops owners: registry stewards per tile. 
• Cadence: S-P tiles quarterly; S-Q tiles quarterly (dashboard) with monthly internal 
refresh. 
• Escalation: Red/amber auto-routes to Owner Matrix (Appendix Y) with due dates 
and DSC options. 
 
Visible change-log (S-8 tile) 
For every release: publish definition_version, what changed, why, comparability impact, and 
next review date (default 30 days). Keep prior definitions accessible with diffs. 

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Example payloads (copy) 
JSON (S-P01) 
{ 
  "tile": "two_key_coverage", 
  "period": "2025-Q3", 
  "value_pct": 78.6, 
  "numerator": 121, 
  "denominator": 154, 
  "source": "TwoKeyRegister+R&W", 
  "last_updated": "2025-09-22T11:05:00+10:00", 
  "definition_version": "1.4.0", 
  "population": "All consequential decisions finalised in quarter", 
  "suppression_applied": "N", 
  "hash": "a1f9…", 
  "contact_owner": "Registry Analytics <analytics@…>" 
} 
CSV headers (all tiles) 
tile,period,value,value_pct,numerator,denominator,source,last_updated,definition_version,po
pulation,suppression_applied,hash,notes 
 
What good looks like / Red flags 
Good: 
• Public site shows six S-P tiles with current quarter and prior four trend points; S-8 
change-log populated; suppression marks visible; definitions link lives next to each 
tile. 
• Internal dashboard shows S-Q tiles with green/amber/red bands; DSC calibration 
items within SLA; reproducible hashes match Appendix T. 
Red flags: 
• High roster_claim_anomaly_rate with flat e_receipt_coverage. 
• Rising time_to_second_key in parallel with lower two_key_coverage. 
• doc_integrity_score <70 for two quarters, or dsc_file_field_concordance <80. 
• navigator_coverage_rate falling while SC line items are removed from plans. 
 
Where to get help / Artefacts & Templates 
• Appendix AL  -  Publication & Dashboard Schema (feeds, API). 
• Appendix T  -  Audit Log Specification (hashing & trace). 
• Appendix H / I / J  -  R&W, Contradiction Matrix, Independent-Reasoning 
Certificate. 
• Appendix E  -  Two-Party e-Receipt schema. 
• Appendix Q  -  OSCE registry + rubrics (licensing). 
• Appendix R  -  DPIA template & privacy hooks. 
• Appendix Y  -  Owner Matrix & Escalation. 

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Summary companion 
One page for executives: “S-Tiles at a glance” - six public metrics + three QA sentinels (S-
Q02, S-Q03, S-Q11), with definitions, suppression note, and the S-8 change-log link. Use as 
the briefing cover for quarterly releases. 
 
 
Appendix T  -  Audit Log Specification 
Events, fields, retention, verification of append-only properties; external audit read-out. 
Owner: Integrity & Privacy 
Interfaces: E-Receipts (Appx E); Roster↔Claim (Appx F); Sanctions Ladder (Appx G); 
Dashboards & Suppression (Appx S/AL); Privacy & Feed Registry (Appx R); R&W / 
Matrix / IRC (Appx H-J); Workforce/IDC & OSCEs (Appx Q); Switching Protocol (Appx 
M); Two-Key Register (IPP); Navigator/Foundational registry. 
 
Why this matters (and why it hasn’t worked) 
When records can be changed without a trace, truth becomes a debate. Past systems mixed 
activity notes with edits, kept weak logs, or let admins rewrite history. A rigorous audit log 
makes decisions and payments provable: every important action is time-stamped, linked to a 
person, hashed, and impossible to quietly delete - and every published number can be 
traced to a feed (Appx R) and definition version (Appx S/AL). 
 
Fast take (read this first) 
• Append-only, tamper-evident journal for every safety, care, integrity, workforce, 
privacy and publication action. 
• Each event captures who/what/when/where/why/result with dual hash chains. 
• Feed/DPIA linkage: every event that creates or publishes data records the feed_id 
and dpia_id (Appendix R). 
• Provenance hashes on exports; monthly anchors published; public tiles list the 
anchor. 
• Least-privilege reads (with read events logged); small-cell suppression enforced at 
export. 
 
Scope 
All systems covered by this White Paper (care records, receipts/claims, investigations, 
decisions, dashboards, OSCEs, switching packs, privacy incidents, Navigator handovers, 
IPP/Two-Key). 
 

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Event model (minimum fields  -  every event must carry these) 
Field Type Meaning / example 
event_id ULID/UUIDv7 Unique event 
ts ISO-8601 Event time with timezone offset 
actor_psn string Pseudonym of human/system actor 
actor_role string e.g., IDC_Lead, Supervisor, System 
provider_abn string 11-digit ABN (where relevant) 
action string See Action catalogue below 
subject_type string e.g., receipt, incident, decision, tile_release 
subject_id string ID of the thing acted on 
object_hash string SHA-256 of new object state/payload 
object_prev_hash string Prior object hash (or null on create) 
event_prev_hash string Hash of prior event (global chain) 
result string success / failure / partial 
reason_code string short code (e.g., CAP_RULE, PRIV_SCAN) 
diff_summary string ≤240 chars human-readable change note (no PII) 
correlation_id string Trace ID across services/batches 
session_id string UI/session correlation 
device object platform, app_version, ip_hash, geo_coarse(optional) 
feed_id string Registry ID from Appx R (e.g., R-E01) or “na” 
dpia_id string DPIA record/version for this flow 
definition_version string Metric/logic SemVer (tiles, checks) 
anchor_ref string YearMonth anchor this event will roll into (YYYY-MM) 
Clock & ordering: servers must NTP sync (≤±2s drift). For burst writes, include a 
monotonic sequence per subject to preserve order. 
 
Action catalogue (grouped) 
Security & access 
• login, logout, password_reset, mfa_enrol, role_grant, role_revoke, consent_viewed, 
read (sensitive read), break_glass_read 
Records & workflow 
• create, update, delete_request (tombstone), restore, attach, detach, export_bundle, 
share_link_create 
Integrity & finance 
• receipt_submit, receipt_attest, crosscheck_run, exception_raise, exception_resolve, 
claim_hold, claim_release 
Safety & quality 

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• incident_log_create, restraint_time_start, restraint_time_stop, review_72h_booked, 
fadeplan_update 
Decisions & governance 
• rw_issue_list_set, rw_evidence_weight_set, cm_conflict_resolve, irc_signoff, 
sanction_stage_set, publication_release, publication_correct, s8_change_note_issued 
Workforce 
• osce_result_recorded, epa_level_set, scope_change_set 
Switching & handover 
• switch_exit_pack_issued, switch_entry_pack_loaded, med_recon_complete, 
navigator_warm_handover_logged 
Privacy 
• dpia_approved, breach_logged, subject_access_provided, erasure_request_recorded, 
small_cell_scan_run, suppression_applied 
Vendors may extend verbs, but must map to a parent group above. 
 
Integrity requirements (tamper-evidence) 
1. Append-only storage (WORM or equivalent). 
2. Dual hash chaining 
o Per-object chain: every change to a subject carries object_prev_hash. 
o Journal chain: every event carries event_prev_hash. 
3. Monthly anchor 
o Compute Merkle root of month’s events; sign; publish anchor + signature; 
store off-site. 
4. Signed exports 
o Any bundle (e.g., receipts, decision pack, tile release) includes a provenance 
hash + anchor reference. 
5. Reconciliation 
o Random audit compares log trails to DB states; mismatches escalate via 
Owner Matrix (Y). 
 
Privacy & safety rules (log smart, not everything) 
• Pseudonymous IDs; identity directory held separately with strict access. 
• Store ip_hash (salted/rotating), not raw IP; geo_coarse only when necessary. 
• diff_summary must never include names/health details. 
• All reads are logged; break_glass_read auto-notifies Privacy Lead + (where safe) the 
person/rep. 

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• Publication exports must run small-cell scan and record suppression_applied with 
definition_version (Appx S/AL). 
• Each event that writes to a dataset must carry feed_id and dpia_id (Appx R). Events 
without them are rejected (except security/auth). 
 
Retention & deletion 
• Default retention: 7 years (align to statute). 
• Serious incidents/decisions: 25 years. 
• Auth logs (login etc.): 2 years minimum. 
• Deletion is logical (delete_request); physical purge only when required by law with 
DPO sign-off → erasure_request_recorded + erasure certificate artifact. 
 
Search & reports (minimum queries systems must support) 
• Who changed X and when? (by subject_id; show object/journal chains). 
• Everything actor Y did in period Z (by actor_psn). 
• Show the chain of a decision (link irc_signoff, R&W weights, Matrix, sanction stage). 
• Receipts altered after submission (flags for back-dating). 
• Publication corrections (what/when/reason/provenance). 
• OSCE/EPA changes (scope adjustments + reasons). 
• Switching pack access (who viewed/downloaded). 
• Feed lineage: list events for feed_id = R-E01 between dates; show dpia_id + 
definition_version. 
• Suppression audit: list small_cell_scan_run and suppression_applied for tile 
releases. 
Indexes: subject_id, actor_psn, action, ts, feed_id, correlation_id. 
 
API surface (reference  -  vendors must implement) 
• POST /audit/events (append one or batch; reject edits; require feed_id/dpia_id when 
applicable) 
• GET /audit/events?subject_id=…&from=…&to=… 
• GET /audit/anchors/:yyyymm (anchor + signature) 
• POST /audit/export (criteria → signed bundle + provenance hash) 
• GET /audit/feeds/:feed_id/lineage?from=…&to=… (feed-scoped view) 
All endpoints: service-to-service auth; MFA for consoles; rate limits. 
 
Publishing & provenance 
• Every dashboard release, sanctions notice, Navigator metric, or public correction 
must log publication_release (or publication_correct) with definition_version, 
feed_id, and a provenance hash that resolves to the month’s anchor. 
• Family-view exports include a short plain-English provenance: “Generated 12 Sep 
2025 from receipts v1; anchor 2025-08; hash …”. 

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What good looks like / Red flags 
Good: every important action has an ordered trail; anchors verify; exports are reproducible; 
feeds link to DPIAs; suppression logged; auditors can answer “who/what/when/why/from 
which feed” in minutes. 
 
Red flags: admins can edit without logs; back-dated batches; missing anchors; diff_summary 
leaks PII; changed tile definitions without s8_change_note_issued; reads unlogged. 
 
Micro-scenarios (worked) 
• Back-dated receipts: 30 tele-receipts appear at once. Log shows receipt_submit with 
same device/app and submitted_at >48h. Cross-check flags; Governance sees the trail; 
payment hold initiates. 
• Decision changed after sign-off: Manager attempts edit; system blocks; requires 
irc_signoff addendum referencing prior hash. Public page shows “Updated” with 
change reason. 
• Dashboard correction: Safety denominator error. publication_correct links to prior 
release hash; S-8 change note logged; page updates within 72h. 
• Suppression proof: Public tile release triggers small_cell_scan_run + 
suppression_applied; auditor queries by feed_id=R-AL01 and confirms 
definition_version + anchor. 
• Navigator handover: navigator_warm_handover_logged for person P; later 
complaint prompts read audit showing who accessed the pack and when. 
 
Quick scripts 
• To a provider manager: “If an action isn’t in the audit log, it didn’t happen. Work 
inside systems that log every change.” 
• To a family: “Your history bundle comes with a fingerprint (hash) tied to a public 
anchor - anyone can check it wasn’t altered.” 
• To a vendor: “Append-only journal, dual hash chains, monthly anchor, feed/DPIA 
linkage, and suppression logging - no silent edits.” 
 
Where to get help / Artefacts & Templates 
• Audit Event Schema (JSON) with enumerated actions 
• Anchoring & hashing guide (Merkle root + publication pattern) 
• Provenance export format (bundle + hash manifest) 
• Access & role matrix (who can read what) 
• Query cookbook (sample SQL/DSL) 
• Erasure certificate form & SOP 
• Privacy guardrails (ip_hash, geo_coarse, no-PII diffs) 
• Feed Registry cross-walk (Appendix R IDs ↔ systems) 

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Summary companion. The audit log is the backbone of truth-by-design: append-only 
records, hash chains and anchors; feeds and DPIAs linked; suppression logged; provenance 
on every public number. That is how this system earns trust. 
 
 
Appendix U  -  Red-Team Scenarios & Reports 
Fraud ring, data breach, provider failure & mass switching, restraint spike, interpreter failure; 
report template and close-out tracker. 
 
Owner: Governance & Integrity 
Interfaces: Safety & Restrictive Practices; Reasons & Weighting / IRC; E-Receipts & Cross-
Checks; Dashboards & Publication; DPIA; Workforce/IDC & Tele-OSCE; First Nations 
Partnership; Rural Micro-Hubs; Complaints & Appeals. 
Why this matters (and why it hasn’t worked) 
We usually discover weaknesses after people are harmed or money is lost. Internal audits 
check paperwork, not reality. Red-teaming uses safe, authorised tests to probe the system 
like an adversary or a stressed shift would - so we fix holes before they become incidents. 
Fast take (read this first) 
• Run quarterly red-team exercises plus spot tests after big changes. 
• Use pre-approved scenarios (below) with clear rules of engagement and privacy 
gates. 
• Every exercise ends with a Plain-English report: what we tried, what broke, how to 
fix it, and by when. 
• Findings route into CAPs, dashboards, and (if needed) the Sanctions Ladder - with 
no retaliation against whistleblowers. 
Scope 
Covers people safety, integrity/claims, access/consent, privacy/publication, workforce 
competence and rural delivery. Applicable across home, community, tele, ED/health, micro-
hubs and switching events. 
 
Program setup (minimum) 
• Governance sponsor & red-team lead named; annual plan approved. 
• Rules of engagement (RoE): safety first; no real harm; minimal data; revert steps 
ready. 
• Safeguards: DPIA completed for any data capture; pseudonym keys; small-cell 
protection in reports. 
• Hotline & safe email for staff/families to suggest scenarios; protections from 
retaliation. 

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• Tracking: each finding becomes an action with owner/date; closure verified. 
 
Scenario library (pick 4-6 per quarter) 
A) Safety & practice 
1. Timing honesty test: Can restraint start/stop be missed or altered without detection? 
2. 72-Hour Review pressure: Will a review slip past 72h without an alert? 
3. PRN drift: Will a sedative be recorded as routine PRN instead of chemical restraint? 
B) Integrity & finance 
4. Roster-receipt mismatch: Attempt to claim 120 minutes against a 90-minute receipt. 
5. Batch-after-the-fact: Try submitting 20 receipts offline beyond the policy window. 
6. Overlap session: Double-book a worker across two people. 
C) Communication access & consent 
7. Interpreter skipped: Hold a plan change without interpreter/Auslan despite trigger. 
8. AAC absent: Arrive to ED without the device; test whether a back-up is offered and 
recorded. 
D) Privacy & publication 
9. Small-cell leak: Try to publish a tile where num <5; check suppression and 
complementary suppression. 
10. Unlogged export: Attempt to export a history bundle without an audit event. 
E) First Nations & cultural safety 
11. Protocol bypass: Schedule during Sorry Business; test whether the Cultural 
Plan/MOU halts and re-routes. 
12. Language mis-match: Request a community language interpreter and check time-to-
fill. 
F) Rural & micro-hub 
13. Link failover: Drop primary internet mid tele-OSCE; test integrity checklist and 
fairness extensions. 
14. Staffing thin-ice: Remove IDC lead; see if roster locks high-risk tasks. 
Add local scenarios as needed; keep the RoE updated. 
 
Execution protocol (how to run a scenario) 
1. Brief & authorise: governance sponsor signs the RoE; notify emergency contacts. 
2. Prime the safety net: designate observers; define hard stop conditions. 
3. Run the scenario: follow steps; record timestamps, screenshots (sanitised), and logs. 
4. Restore state: undo any temporary changes; confirm normal operations. 

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5. Debrief the same day: capture what worked/failed; draft the one-page summary. 
6. File evidence: to the audit log with a provenance hash. 
 
Scoring rubric (rate each finding) 
• Severity (S): impact if real (Low/Med/High/Critical). 
• Exploitability (E): effort to trigger (One-click / Some skill / Complex). 
• Reach (R): how many people/sessions it could affect (Few / Many / Sector). 
• Fix readiness (F): we can fix now (High) vs needs system change (Low). 
Priority = S + E + R (4-point scale mapped to colours). Use F to choose the owner and 
timeline. 
 
Report format (one page + evidence bundle) 
Header: scenario ID & name • date • team • RoE link • DPIA ref • provenance hash 
What we tried (≤5 lines) 
What happened (facts & timestamps) 
What should have happened 
Why it matters (risk in plain English) 
Priority & scores (S/E/R/F) 
Actions (owner/date/verification) 
Lessons (1-3 lines) 
All attachments are de-identified and hashed; public summaries avoid small-cell risk. 
 
Roles & responsibilities 
• Red-team lead: runs scenarios, keeps RoE, files to audit log. 
• Observer(s): watch for safety/privacy; can pause. 
• System owner(s): receive actions and report closure. 
• Governance panel: reviews monthly; escalates to Sanctions if repeat or severe. 
• Comms lead: prepares plain-English notes for staff/families where appropriate. 
 
What good looks like / Red flags 
Good: regular, safe tests; quick, specific fixes; clear notes on the dashboards; no blame for 
reporting; repeat failures drop. 
Red flags: tests blocked; findings buried; same hole every quarter; retaliation against staff 
who raised concerns. 
 
Micro-scenarios (worked) 
• E-receipt decline loop (E7): Red-team “family” declines three receipts. Courtesy-
check fires; supervisor resolves two; one remains and blocks payment - Pass. 

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• Suppression bypass attempt: Publishing a suburb tile would reveal one family. 
System applies suppression and complementary suppression - Pass. Method note 
improved. 
• Interpreter skipped in plan change: Team proceeds without Auslan. Red-team 
flags; IRC later shows “Fail (Lawfulness/Candour)”. Action: booking rule in system, 
dashboard tile added - Fixed in 10 days. 
• Back-dated batch: 25 tele claims appear with identical minutes. Cross-check + Audit 
Log catch it; targeted hold triggers; provider coached; match-rate recovers - Closed. 
 
Quick scripts 
• Invite to staff: “Help us break the system safely so it protects people better. No 
blame - just fixes.” 
• To families: “We test our systems like seatbelts. If we find a flaw, we fix it and tell 
you what changed.” 
• To a provider manager: “If a finding repeats next quarter, it escalates to the 
sanctions ladder.” 
 
Privacy & ethics 
• Minimise personal data; use test accounts where possible. 
• Never simulate harm without explicit safeguards. 
• Reports carry no names; identifiers replaced by pseudonym keys. 
• First Nations scenarios are co-designed with the local cultural authority; publication 
wording reviewed. 
 
Where to get help / Artefacts & Templates 
• Red-Team RoE pack (authorisation, hard stops, contacts) 
• Scenario cards (A-F above, step-by-step) 
• One-page report template (with S/E/R/F scoring) 
• CAP tracker (owner/date/verification; dashboard feed) 
• Debrief checklist (facts, why, fix, lesson) 
• Whistleblower & anti-retaliation notice 
• Provenance & hashing script (attach to audit log) 
 
Summary companion. Decisions rely on the governing sections named in Governance & 
Integrity, Safety & Restrictive Practices, Truth-by-Design, DPIA and Public Reporting 
policies. 
 
 

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Appendix V  -  Peer Calibration Rubrics & Quality Summary Template 
Double-rating sheets (IDC observation, review quality, receipt candour, R&W structure); 
quarterly quality summary layout. 
 
Owner: Quality & Independent Verification 
Interfaces: Reasons & Weighting (Appx H); Contradiction Matrix (Appx I); IRC (Appx J); 
Workforce/OSCEs (Appx Q); Sanctions Ladder (Appx G); Dashboards & Suppression (Appx 
S); DPIA (Appx R); Audit Log Spec (Appx T); Red-Team (Appx U). 
Why this matters (and why it hasn’t worked) 
Different reviewers have reached different outcomes on the same facts. OSCE examiners 
score unevenly. Families call this “postcode justice.” Calibration fixes this by scoring the 
same cases together, using clear rubrics, checking agreement, and then tightening the rules 
or retraining where drift appears. 
Fast take (read this first) 
• Calibrate monthly for each stream: Decisions (R&W/IRC), OSCE examiners, and 
Safety Logs. 
• Use a 5-case pack per stream; score blind, then compare. 
• Targets: ≥80% agreement on critical items and kappa ≥0.60 (substantial) across 
raters. 
• Write a one-page Quality Summary with results, top errors, fixes and owners. 
• If below target → immediate micro-training + re-check within 14 days. 
• File packs, scores and summaries to the audit log with a provenance hash. 
Scope 
All reviewers, examiners, chairs and supervisors who make or quality-check decisions, mark 
OSCEs, or sign off restrictive-practice logs. 
 
Rubrics (score 0-3 unless marked “critical”) 
0 Not done/unsafe • 1 Weak/partial • 2 Acceptable • 3 Strong/best practice 
Items in bold are critical: a 0 = automatic “Not acceptable” for the case/station. 
A) R&W / IRC Decision Rubric (per case) 
Criterion 0 1 2 3 
Issues listed first none 
vague or 
mixed with 
findings 
clear list but 
incomplete clear, complete, numbered 
Evidence table & 
weights (0-4) none some items 
unweighted 
all weighted, 
brief reasons 
weighted + consistency 
checks noted 

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Criterion 0 1 2 3 
Contradictions 
resolved (principles 
cited) 
none gesture to 
conflict only 
principles 
listed; 
decision 
stated 
principles + ≤25-word reason 
per conflict; confidence 
recorded 
Applied tests 
(necessity, least-
restrictive, lawfulness, 
candour, privacy) 
none partial or 
misapplied all applied applied with precise evidence 
IDs 
Findings cite Evidence 
IDs & weights none some citations all cited all cited + clean numbering 
(≤5) 
Actions are specific + 
owner + date + 
verification 
none vague (“be 
vigilant”) 
specific with 
owner/date 
specific + verification step 
fits the finding 
Plain-English Reasons 
(≤140 words) missing/jargon long or 
unclear 
clear & 
respectful 
clear + accessible format 
noted (interpreter/AAC) 
Privacy/DPIA respected breach risk not 
addressed 
minimum 
data + no 
names 
plus suppression/publication 
notes if relevant 
Critical fails: no issues list; no evidence IDs in findings; no actions/verification; privacy 
breach. 
B) Contradiction Matrix Rubric (per conflict row) 
Criterion 0 1 2 3 
Conflict is atomic & plain blended broad single point single point + narrow tag 
(time/method/law) 
Principles used (by 
number) none 1 weak ≥2 relevant ≥2 + short why (≤25 words) 
Preferred item stated missing implied stated stated + confidence + follow-up if 
<High 
C) OSCE Examiner Calibration (per station) 
Criterion 0 1 2 3 
Critical items applied consistently not 
aligned often off mostly 
aligned 
fully aligned across 
raters (≥90%) 
Timing & integrity (checklist, identity, 
dual cam if tele) gaps minor 
misses complete complete + clean notes 
Feedback style (brief, specific, safe) missing generic specific specific + next step 
Accessibility (interpreter/AAC, fair 
extensions) ignored ad-hoc provided provided + recorded 
Station acceptability rule: any examiner marking a critical pass where others mark fail → 
flagged for re-brief and re-check. 
D) Restrictive-Practice Log & Timekeeping (spot-check rubric) 

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Criterion 0 1 2 3 
Start/stop timed (ISO or hh:mm) none one end 
only 
both 
ends 
both ends + seconds or device 
time 
Alternatives tried (green→amber 
order) none vague listed listed in order that matches Fade 
Plan 
Authoriser captured none late on time on time + contactable 
72-Hour review booked no >72h ≤72h ≤72h + summary filed 
 
Running a calibration session (60-90 minutes) 
1. Pick the pack: 5 recent, de-identified cases/stations/logs (mix easy/hard). 
2. Blind score (20-30 min): everyone completes rubrics solo. 
3. Compare & compute (10 min): show % agreement and kappa; mark drifts. 
4. Discuss (20 min): where did ratings split? tie back to standards. 
5. Decide fixes (10 min): update examples, tighten wording, plan micro-training. 
6. Record & file (5 min): Quality Summary + actions → audit log with hash. 
 
Measures & thresholds 
Metric Target Escalation 
Agreement on critical items ≥ 80% <80% → retrain + re-check in 14 days 
Overall kappa (per stream) ≥ 0.60 <0.60 two months running → governance 
review 
Rework rate (decisions returned) ↓ over 
quarter spike → cause analysis in next calibration 
Time to close actions from 
calibration ≤ 30 days overdue → Sanctions Stage 1 (internal) 
 
Quality Summary  -  One-Page Template (publish internally) 
Header: Month • Stream (Decisions / OSCE / Logs) • Team • Provenance hash 
Results (traffic lights) 
• Critical-item agreement: __% (Target ≥80%) 
• Kappa: __ (Target ≥0.60) 
• Cases/stations scored: __ 
Top 3 drifts 
1.  
2.  
3.  
Fixes decided 
• Rule/wording change: __________________ (owner/date) 
• Micro-training: ________________________ (owner/date) 
• Example library update: ________________ (owner/date) 

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Good practice examples (IDs) 
•  
Risks & notes (≤4 lines) 
 
Sign-off: Lead / Date • Filed to audit log (event ID ______) 
 
 
What good looks like / Red flags 
Good: clear rubrics; same facts → same score; fast micro-training; fewer reworks; families 
see consistent reasons. 
 
Red flags: scoring by seniority; long debates without rules; kappa never computed; actions 
not closed; repeat drift in the same area. 
 
Micro-scenarios (worked) 
• Dueling findings: Two reviewers split on “least-restrictive”. Matrix shows video 
(E01, w4) outweighs late note (E02, w2). Agreement rises to 92% after adding that 
example to the pack. 
• OSCE drift: One examiner passes candidates who miss the “start/stop timing” 
critical. Re-brief + shadowing fixes alignment the same month. 
• Log gaps: Authoriser field often blank. Calibration triggers a log redesign + 
coaching; blanks drop by 70% in 6 weeks. 
 
Quick scripts 
• Invite: “Same facts should lead to the same score. We’ll test ourselves together and 
tighten the rules where we drift.” 
• Close-out: “Here’s the one-page summary: what split, what we fixed, and who owns 
it by when.” 
 
Where to get help / Artefacts & Templates 
• R&W/IRC Calibration Rubric (0-3 with critical fails) 
• Contradiction Matrix mini-rubric 
• OSCE Examiner calibration pack (station keys + marking guide) 
• Restrictive-Practice Log spot-check sheet 
• Kappa & agreement calculator (spreadsheet/CSV headers) 
• Quality Summary one-pager 
• Example library (good/poor anonymised cases) 

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Summary companion. Decisions rely on the governing sections named in Independent 
Verification, Workforce/IDC, Truth-by-Design, DPIA and Governance policies. 
 
Appendix W  -  Evaluation Access Protocol 
Dataset inventory, privacy conditions, lineage map (capture→transform→tile), right-to-
publish clauses. 
 
Owner: Evaluation & Governance 
Interfaces: DPIA (Appx R); Privacy & Audit Log (Appx T); Dashboards & Suppression 
(Appx S); First Nations Partnership (Appx O); Interpreter/Auslan/AAC Toolkit (Appx N); 
Family View & E-Receipts (Appx E); R&W / IRC (Appx H-J); Switching Protocol (Appx 
M). 
Why this matters (and why it hasn’t worked) 
Evaluations have arrived with clipboards, big promises and vague permissions. People are 
asked the same questions twice, raw data walks out the door, and results come back a year 
later - if at all. This protocol gives clear, fair access that protects privacy, respects culture, 
and still lets independent evaluators see what’s real and feed fixes back quickly. 
Fast take (read this first) 
• Access is tiered (A-E) and purpose-based. Start at the lowest tier that works. 
• Consent is real: accessible, recorded, revocable; interpreters/AAC offered. 
• Data minimised: pseudonym keys, suppression, secure “data room”, no raw exports 
without approval. 
• Independent & transparent: ethics approval, conflicts declared, methods pre-
registered; share a Plain-English summary back to participants. 
• Everything logged in the audit log; DPIA approved before fieldwork. 
Scope 
All external and internal evaluations, audits, research collaborations and pilots that touch 
people, records, or operational data across any setting. 
 
Access tiers (A-E)  -  use the lowest tier that meets the question 
A. Public (no application needed) 
• What: published dashboards & method notes (Appx S), policies, anonymised case 
examples. 
• Use when: high-level benchmarking, trend sense-check. 

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B. Participant-consented “Family View” 
• What: the person/representative shares their own history (receipts, plans, outcomes). 
• Access: in the room with them; no copies unless they request a download. 
• Record: consent mode, timestamp, who saw what. 
C. On-site provider records (supervised) 
• What: read-only access to specified files; screen-share or supervised read. 
• Controls: no screenshots; notes de-identified; extracts requested via DPO route. 
• Use when: you need context behind events or to verify procedures. 
D. Secure data room (de-identified dataset) 
• What: pseudonym keys; coarse geography; small-cell suppression; date lags; k-
anonymity. 
• Controls: virtual desktop; queries run server-side; outputs scanned for suppression; 
no USB / email out. 
• Use when: quantitative analysis is needed across many people or sites. 
E. Identified observation/interview (with consent) 
• What: interviews, focus groups, shadowing, OSCE observation. 
• Controls: Interpreter/Auslan/AAC as needed; optional audio/video only if DPIA 
allows; recordings stored encrypted with set retention. 
• Use when: the evaluation question needs lived experience or practice observation. 
Escalation rule: if a lower tier won’t answer the question, justify the move up in the DPIA 
and get approval. 
 
Consent & participation (make it real) 
• Offer access supports (Interpreter/Auslan/AAC); use teach-back. 
• Plain-English consent must state: what, why, who sees it, retention, withdrawal path, 
and that services don’t depend on saying yes. 
• Record: mode (tap/PIN/biometric/verbal-witnessed/alt-comm), date/time, and any 
limits (topics off-limits, “no recording”, etc.). 
• First Nations: follow the MOU & Cultural Plan (Appx O); community consent may 
be required for community-level data or publication wording. 
Quick consent script (plain): 
“We’re evaluating how well this service works. You can say yes or no. If yes, we’ll look at 
[describe tier], keep the minimum data, and share a short summary with you. Saying no won’t 
change your supports.” 
 
Apply for access (what evaluators submit) 
1. Purpose & questions (1-2 pages, plain English). 

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2. Access tier(s) requested and why lower tiers won’t do. 
3. Method & sampling (who, how many, how chosen; power & equity notes). 
4. Ethics & independence (committee approval or exemption; conflicts of interest). 
5. DPIA (Appx R) with data inventory & controls. 
6. Consent materials (Plain-English + Easy Read; interpreter/Auslan availability). 
7. Return-of-results plan (what participants get back, when). 
8. Data handling (storage, retention, publication rules). 
9. Team (roles, checks, cultural brokers if applicable). 
Turnaround: triage in 5 business days; decision/conditions within 15 (complex items may 
need panel review). 
 
Sampling & fairness rules 
• Minimum burden: avoid duplicate asks; re-use existing data where valid. 
• Equity: include people who use interpreters/AAC; offer after-hours/remote options; 
reimburse time/transport. 
• Do no harm: avoid recruitment via workers who hold power over the person; provide 
a safe decline path. 
• First Nations: co-design sampling with the local ACCO/cultural authority. 
 
Data handling & security (all tiers C-E) 
• Pseudonym keys only; names live in a separate directory. 
• Small-cell suppression and rounding rules (Appx S) for any published crosstabs. 
• Provenance: analysis bundles hashed; codebooks/versioning recorded. 
• No raw exports from data room; approved aggregates only; complementary 
suppression applied. 
• Audit log every access/query/export (Appx T). 
• Retention: keep the minimum for the minimum time; set auto-purge. 
 
Interviews & observation (E-tier)  -  minimum protocol 
• Environment: private, quiet; the person chooses who’s present. 
• Access: Interpreter/Auslan/AAC set up; yes/no method confirmed. 
• Topics: explain sensitive areas; allow “skip” on any question. 
• Recording: only with consent & DPIA; stop immediately if asked. 
• Safety: if harm risk appears, pause and follow the practice escalation path. 
• Debrief: give contact for questions/withdrawal; advise on complaints path. 
 
Independence & publication 
• Pre-register key outcomes & analysis plan (or note why not). 
• Declare conflicts (funders, roles, relationships). 
• Plain-English summary (≤2 pages) must be returned to participants/families and 
posted with the report. 

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• Small-cell & cultural review for any public wording (Appx S & O). 
• Right of reply: providers can correct facts (not opinions) before final release; 
responses logged. 
 
What good looks like / Red flags 
Good: lowest viable access tier; real consent with supports; de-identified analysis in a secure 
room; timely, plain-English feedback; community protocols followed; full audit trail. 
Red flags: “give us everything” requests; family used as interpreters; raw data emailed; 
findings without suppression; no summary back to participants. 
 
Micro-scenarios (worked) 
• Quick study using existing data (Tier D): Evaluator analyses participation trends in 
the data room; exports rounded tables with suppression; two privacy risks found and 
fixed; 2-page summary sent to families. 
• Interview on switching (Tier E): Person chooses Auslan + DI; AAC board used; no 
recording by choice; notes de-identified; summary paragraph shared with the person 
for member-check. 
• Cultural review before publication: Draft includes a suburb map; ACCO requests 
aggregation to district; wording updated; report released with a cultural note. 
 
Quick scripts 
• To an evaluator (triage): “Start with Public/Family View. If that won’t answer your 
question, show us why in your DPIA and we’ll consider Tier C-E.” 
• To a participant: “You can read or hear a short summary of what we learned. If you 
want a copy of your own data, we’ll help you get it.” 
• To a provider manager: “Evaluation can’t hold up care or billing. If we need a data 
fix, we’ll route it through governance while supports continue.” 
 
Where to get help / Artefacts & Templates 
• Evaluation Access Request form (purpose, tiers, DPIA link, ethics, conflicts) 
• Plain-English & Easy Read consent packs (with interpreter/Auslan options) 
• Data room user agreement (no raw exports; suppression checks) 
• Participant summary template (≤2 pages; multi-language/Auslan/audio) 
• Sampling & equity checklist 
• Cultural review checklist (with ACCO sign-off) 
• Provenance & audit checklist (hashes, event IDs) 
 
Summary companion. Decisions rely on the governing sections named in DPIA & 
Privacy, First Nations Partnership, Truth-by-Design, and Independent Verification 
policies. 

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Appendix X  -  ROI Workbook Notes & Assumptions Register 
Parameter list (unit costs, effect sizes, lags, discount rate); change log; sensitivity guidance. 
 
Owner: Finance & Governance 
Interfaces: Dashboards & Suppression (Appx S); E-Receipts (Appx E); Roster↔Claim 
Cross-Checks (Appx F); Workforce/IDC & OSCEs (Appx Q); DPIA (Appx R); Audit Log 
Spec (Appx T); Evaluation Access (Appx W); Red-Team (Appx U); Switching Protocol 
(Appx M). Attached excel workbook. 
Why this matters (and why it hasn’t worked) 
“Benefits” have been claimed without showing the maths or the assumptions. Costs were 
counted, but not avoided re-work, reduced travel, fewer incidents, or faster assessments. This 
appendix makes return-on-investment traceable: a small set of measures fed by receipts and 
logs, a plain register of assumptions, and repeatable rules that avoid double-counting. 
Fast take (read this first) 
• Three benefit types: 
1. Cash-releasing (real $$ outlays drop). 
2. Cost-avoided (likely $$ pressures prevented). 
3. Impact index (non-$ improvements that still matter). 
• Keep one baseline window and one change window (e.g., baseline = prior 6 months; 
change = last 6). 
• Link numbers directly to receipts, cross-checks, OSCE results and dashboards. 
• Record every valuation in the Assumptions Register with source, bounds and owner. 
• Show NPV, BCR, payback months with sensitivity (Low/Default/High). 
• Privacy: publish provider-level ROI only; no person-level stories without consent. 
Scope 
All initiatives in this paper (e-receipts, cross-checks, participation scheduling, 
interpreter/Auslan/AAC, rural micro-hubs, OSCE & IDC uplift, publication). Use with 
provider pilots and sector roll-outs. 
 
What counts (definitions & examples) 
A) Costs (separate one-off vs ongoing) 
• Staff time (set-up, training, running cross-checks, courtesy-checks) 
• Interpreter/Auslan & AAC spend 
• OSCE delivery & remediation time 
• Micro-hub kit, connectivity, venue fees 
• Software, hosting, support, change management 
• Governance/compliance effort (sanctions, publication) 
• Switching support (temporary overlap, travel) 

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B) Benefits 
Cash-releasing 
• Reduced travel km/hrs (micro-hubs, better routing) 
• Fewer cancelled sessions (backup plans; schedule quality) 
• Lower rework/admin minutes (e-receipt automation; cross-check pass) 
Cost-avoided 
• Over-claim prevention/repayments avoided (match-rate ↑) 
• ED visits/incidents avoided (communication access; de-escalation) 
• Agency/legal costs avoided (clear reasons; fewer appeals) 
Impact index (publish, not monetise) 
• Restraint minutes ↓ 
• Participation variety/role depth ↑ 
• Time-to-OSCE / staff in-scope ↑ 
• Complaints resolved inside standard ↑ 
Rule: use cash-releasing for hard $$, cost-avoided when evidence shows strong likelihood, 
and index when monetisation would be speculative. 
 
Measurement notes (how we compute) 
1. Baselines & windows 
o Choose windows that avoid season spikes (e.g., rolling 90d for safety; 28d for 
integrity). 
o Baseline = last stable period before change; Change = most recent period after 
change matured. 
2. Attribution & deadweight 
o Attribution = share of improvement due to this initiative. Default 0.6 (60%) 
unless stronger design (e.g., stepped-wedge, red-team control) supports more. 
o Deadweight = improvement that would’ve happened anyway. Default 0.2 
(20%). 
o Drop-off (benefit fade) per year: default 0.15 (15%) unless refreshed by 
policy. 
3. Avoid double-counting 
o If you monetise “admin minutes saved”, do not also monetise the same 
minutes as travel saved. 
o If ED avoidance is counted, don’t add the same minutes as “incident admin 
saved”. 
4. Discounting & inflation 
o Real terms. Discount rate d = [POLICY] (e.g., 3-7%). CPI applied to cost 
lines only. 
5. Rounding & suppression 
o Use Appx S rules for public numbers; internal workbook can keep exacts. 

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Formulas (used in the workbook) 
• Change in metric (Δ) = value_change_window - value_baseline 
• Net attributable change = Δ × (1 - deadweight) × attribution 
• Annualised benefit = net attributable change × unit valuation × (1 - drop-off) 
• NPV = Σ (benefit_t - cost_t) / (1 + d)^t 
• BCR (benefit-cost ratio) = Σ benefit_t / Σ cost_t 
• Payback months = months until cumulative (benefit - cost) ≥ 0 
Unit valuation examples live in the Register (e.g., $ per km, $ per cancelled session, $ per 
avoided ED visit). 
 
Assumptions Register (what every line must include) 
Field What to enter 
Code Short ID (e.g., VAL_TRAVEL_KM) 
Definition What this assumption values or sets 
Unit $, %, km, min, rate, etc. 
Default Default value used in “central” case 
Low / High Sensitivity bounds 
Type Cash-releasing / Cost-avoided / Index 
Source Dataset, study, tariff, or policy note 
Evidence strength High / Medium / Low 
Owner Role/name responsible for this assumption 
Next review Date 
Linked KPI Tile or metric (Appx S code) 
Notes / change-log Why it changed; decision ID (audit log link) 
Starter list (illustrative defaults  -  set locally in AA) 
• VAL_TRAVEL_KM (Unit $/km): Default 0.78 | Low 0.60 | High 1.10 | Source: fleet/ATO 
mix | Type Cash 
• VAL_CANCELLED_SESSION (Unit $/session): 45 | 30 | 70 | Source: payroll + overhead | 
Cash 
• VAL_ADMIN_MIN (Unit $/minute): 0.70 | 0.50 | 1.00 | Source: blended wage | Cash 
• VAL_ED_VISIT_AVOIDED (Unit $/visit): 820 | 600 | 1500 | Source: local health tariff | 
Avoided 
• ATTR_DEFAULT (Attribution %): 0.60 | 0.40 | 0.80 | Source: method note | Meta 
• DEADWEIGHT_DEFAULT: 0.20 | 0.10 | 0.30 | Meta 
• DROPOFF_DEFAULT: 0.15 | 0.10 | 0.30 | Meta 
• DISCOUNT_RATE: 0.05 | 0.03 | 0.07 | Finance policy | Meta 
(Populate the full table in Appendix AA; each line gets an owner and review date.) 
 
Worked mappings (data → benefit lines) 
• Cross-check match-rate ↑ → Over-claim prevention 
o Δ = pass_rate_change × claims_volume × avg_claim_value × ATTR 

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• Cancellations ↓ (from schedule + backup plans) → Sessions saved 
o Δ sessions × avg minutes × VAL_ADMIN_MIN (or tariff) 
• Travel km ↓ (micro-hubs) → Fuel/vehicle hours saved 
o Δ km × VAL_TRAVEL_KM 
• Time-to-OSCE ↓ / currency ↑ → Incidents avoided (risk proxy) 
o Δ currency × risk reduction factor × VAL_ED_VISIT_AVOIDED (if 
evidenced) 
• Interpreter/Auslan/AAC use ↑ → Contested decisions ↓ / sedation avoided 
o Δ contested-rate × case volume × cost-avoided tariff (if evidenced) 
• Restraint minutes ↓ → Impact index (publish; do not monetise unless approved) 
 
How to run the workbook each month (10 steps) 
1. Lock the period (period_end = last day of month). 
2. Pull inputs from tiles (Appx S) + receipt/claim extracts. 
3. Validate counts against provenance hash; re-run if mismatched. 
4. Compute Δ vs baseline; apply attribution & deadweight. 
5. Apply valuations from the Register (central case). 
6. Roll NPV/BCR/payback over 12-24 months. 
7. Run sensitivity (Low/High bounds). 
8. Create one-page ROI summary (see below). 
9. File workbook & summary to audit log (event + hash). 
10. Publish provider-level summary (safe aggregates only). 
 
One-page ROI Summary (internal; publishable with suppression) 
Header: Initiative • Provider/Region • Period end • Provenance hash 
Costs (this period): $____ one-off | $____ ongoing 
Benefits: Cash-releasing $____ | Cost-avoided $____ | Impact index: list (no $) 
NPV / BCR / Payback: $____ | . | __ months 
Top drivers: (1-3 lines) 
Assumptions changed: Codes & reason (from Register) 
Risks & notes: small-cell, attribution caveats 
Sign-off: Finance • Governance • Practice lead • Date 
 
What good looks like / Red flags 
Good: all benefits trace to data; assumptions owned and reviewed; sensitivity shown; ROI 
improves as operations stabilise; public note is short and honest. 
Red flags: “soft” benefits monetised without source; double-counting; person-level 
publication; moving baselines; missing hashes; BCR quoted without costs. 
 
Micro-scenarios (worked) 
• Micro-hub pilot: 1,800 km/month travel saved; cancellations down 22%; OSCE 
currency +15 pts. Central case: BCR 1.7, payback 7 months. 

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• Interpreter uplift: Fulfilment +30 pts; contested decisions -40%. Cash costs rise 
slightly; cost-avoided from appeals/ED trips bigger → BCR 1.3. 
• Cross-check deployment: Match-rate up to 98.8%; over-claim prevention $__/mo; 
admin minutes down 12%. Payback 3 months. 
 
Quick scripts 
• Board: “This is conservative: cash first, cost-avoided second, impact shown as an 
index. Every dollar has a source and a hash.” 
• Provider: “If you keep cancellations down and travel local, the model pays for itself 
inside a year - here’s where the savings land.” 
• Public note: “We report savings only when the maths is traceable and privacy-safe.” 
 
Where to get help / Artefacts & Templates 
• Assumptions Register (CSV headers + example lines) 
• ROI workbook shell (inputs, formulas, sensitivity toggles) 
• One-page ROI Summary (fillable) 
• Valuation library (unit costs/tariffs, evidence strength) 
• Attribution guide (stepped-wedge, DiD, red-team controls) 
• Double-counting checklist 
• Provenance & filing checklist (hashes, audit events) 
 
Summary companion. Decisions rely on the governing sections named in Finance policy, 
Truth-by-Design, DPIA, Audit Log and Public Reporting rules. 
 
Appendix Y  -  Owner Matrix & Escalation Playbook 
Owner: Governance & Operations (Accountable Executive: Director, Operations) 
Interfaces: Safety & Restrictive Practices; Minimum Investigation Standard (MIS); Reasons 
& Weighting (Appx H); Contradiction Matrix (Appx I); IRC (Appx J); DPIA (Appx R); 
Dashboards & Suppression (Appx S); Audit Log Spec (Appx T); Sanctions Ladder (Appx G); 
Evaluation Access (Appx W). 
Why this matters (and why it hasn’t worked) 
When ownership is fuzzy and escalation paths are unclear, serious issues stall, people stay at 
risk, and fixes drift. Past playbooks doubled-up roles, set no response times, and rarely closed 
the loop. A single owner per decision area, clear severity levels, and tight close-out rules 
make responses fast, fair and auditable. 
Fast take (read this first) 

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• One accountable owner (A) per decision area. Never more than one “A”. 
• Four severity bands (S0-S3) with fixed response times and who leads. 
• Stop-rules trigger an immediate fix-forward sprint. 
• Close-out requires MIS checklist + R&W summary + actions with owners/dates. 
• Everything logged to the audit log with a provenance hash. 
Scope 
All providers and settings under this White Paper: incidents, safety practices, privacy events, 
integrity exceptions, workforce scope/OSCE currency, publication errors, and rural continuity 
issues. 
 
Key terms (plain) 
• Owner (A): single person accountable for outcomes; may delegate work, not 
accountability. 
• Responsible (R): the doers (team/role running the task). 
• Consulted (C): inputs shape the decision. 
• Informed (I): must be told; don’t decide. 
• S-level: severity band that sets timers and leadership. 
• Stop-rule: pre-agreed condition that pauses business-as-usual and starts the playbook. 
 
Escalation ladder (S0-S3) 
Level Typical triggers (examples) First 
response time Lead on scene 
S0  -  
Critical 
Life-threatening risk; sentinel restraint/sedation; 
medication error with harm; missing person; 
major privacy breach (raw PII) 
Immediate 
(0-15 min) 
Site Incident Lead → 
On-call Manager; A 
notified ≤30 min 
S1  -  
High 
Emergency restraint; repeated seizure rescues 
above threshold; mealtime/IDDSI failure; 
supervision lapse; serious complaint 
60 min On-call Manager; A 
joins ≤2 h 
S2  -  
Medium 
KPI breach x2 days (e-receipt <85%, incident 
timeliness <95%); documentation-integrity fail; 
preview data errors 
By end of day Functional Lead; A 
reviews ≤24 h 
S3  -  Low 
Single breach with no immediate risk; small 
data/roster mismatches; complaints resolved 
same day 
≤2 business 
days 
Team Lead; weekly 
review by A 
Auto-promote if unsure. S-level can only be downgraded by the A after facts are recorded. 
 
Stop-rules (pre-wired triggers) 
Start the playbook immediately and brief the A when any occur: 
• Sentinel event (choking, severe injury, chemical restraint outside plan). 
• Two consecutive days below critical KPIs (e-receipt coverage or incident timeliness). 
• OSCE inter-rater reliability < 0.75 at any hub. 

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• Privacy breach with raw identifiers or unsuppressed tiny cells. 
• Restrictive-practice minutes rising two quarters with no fade plan. 
 
How escalation runs (5 steps) 
1. Make safe & record 
Stabilise the person/situation; start the incident timer; capture facts only. 
2. Notify per ladder 
Page on-call; name the current A from the matrix; confirm S-level and timers. 
3. Assign roles & scope 
o Incident Manager (R) runs the response. 
o Owner (A) sets scope/resources and any external notifications 
(ED/regulator/police/OPG). 
o Comms lead handles family/staff/partner updates. 
o Start MIS checklist; open Contradiction Matrix if accounts conflict. 
4. Fix-forward sprint (time-boxed) 
o S0/S1: actions in hours; S2: within 1-3 days; S3: within 5-10 days. 
o Apply relevant standards (Restraint Timing, Mealtime/IDDSI, DPIA, etc.). 
5. Close-out & learning 
o File R&W (issues → weighted evidence → findings). 
o Log corrective actions (owner/date/verification). 
o Update Publication Notes for next release; schedule learning debrief ≤72 h 
for S0. 
 
Owner matrix rules (how to keep it clean) 
• Exactly one A per row; list R/C/I clearly. 
• Name alternates for the A and on-call; include after-hours numbers and backup 
channel (SMS + phone; radio for rural). 
• Replace names the day roles change; review the matrix monthly. 
• Anyone with lapsed licence/scope cannot be the A for that area. 
• Post the live matrix in the staff app and at the huddle board. 
 
Measures (publish internally; some to dashboards) 
• decision_timely_le_20bd_pct (tribunal/decision timeliness) 
• mis_compliance_pct (MIS used & complete) 
• stop_rule_trigger_count and mean_time_to_contain (by S-level) 
• external_notify_within_sla_pct (privacy/regulator/tribunal) 
• repeat_incident_30d_pct (by category) 
• owner_matrix_currency_pct (rows with a current A + alternates) 
 
Micro-scenarios (worked) 

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• S0  -  Mealtime sentinel: Choking event. On-call triggers S0; A authorises 72-hour 
review; mealtime plan re-checked; kitchen audit same day; family briefed; publication 
note queued. 
• S1  -  Privacy breach: Email with raw names. Contain ≤60 min; notify privacy 
officer + A; regulator notice within statutory window; DPIA addendum filed; staff re-
briefed. 
• S2  -  KPI drift: E-receipt coverage <85% two days. Stop-rule fires; workflow 
coaching; sampling plan; preview notes updated. 
• S3  -  Single documentation miss: Correct same day; add to supervisor’s monthly 
sample. 
 
Quick scripts 
• To staff (start of shift): “If a stop-rule fires, page on-call and start the pack. One 
owner per area - check the board for who’s A today.” 
• To families (S0/S1): “We’ve paused normal routines to make things safe. Here’s 
what happened, who’s in charge, and what will happen in the next few hours.” 
• To providers: “If it isn’t in the audit log, it didn’t happen. Close-out needs MIS + 
R&W + dated actions.” 
 
Where to get help / Artefacts & Templates 
• Y1. Owner Matrix (R/A/C/I) sheet  -  Decision Area | A (name, role, mobile, alt) | R 
(team) | C | I | Hours | Notes. 
• Y2. On-Call Roster & Handover Card  -  week grid; coverage; escalation numbers; 
rural radio fallback. 
• Y3. Escalation Decision Tree (S0-S3)  -  one-page triggers/timers. 
• Y4. Close-Out Pack  -  MIS checklist + R&W one-pager + Publication Notes stub. 
• Y5. Family/Partner Comms Scripts  -  S0/S1 only (plain English). 
 
Summary companion. Decisions rely on the governing sections named in Safety & 
Restrictive Practices, MIS, Truth-by-Design (R&W/IRC), DPIA, Dashboards & 
Suppression, Audit Log and Sanctions policies. 
 
Appendix Z  -  Practice-Note Crosswalks (including “Thriving Kids”) 
Purpose 
Collect the practice-note crosswalk tables that translate everyday situations into the 
Standards. Use for training, OSCE prep, supervision and quality reviews. 
Owner: Practice & Governance 
Interfaces: Choice & Control; Communication Access (Appx N); Accessible Plan Pack 
(Appx K); Weekly Community Schedule & Participation (Appx L); Handover & Medication 

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Reconciliation (Appx D); Reasons & Weighting / IRC (Appx H-J); DPIA (Appx R); 
Evaluation Access (Appx W); Owner Matrix (Appx Y). 
Why this matters (and why it hasn’t worked) 
Great practice notes exist, but they live in PDFs and long emails. Staff don’t know what to 
do today, or how a note fits the standards. Crosswalks turn each practice note into a one-
pager of actions with links to the exact clauses, templates and measures - so workers can 
apply it the same way, every time. 
Fast take (read this first) 
• Make a one-page crosswalk per practice note (including “Thriving Kids”). 
• Show triggers, do/never do, who owns it, which forms to use, and how we’ll 
measure it. 
• Keep a second table that maps the note’s sections to the Standard/Appendix 
clauses. 
• Store crosswalks with a provenance hash and review them six-monthly or when the 
note changes. 
Scope 
All active practice notes, guidance letters and toolkits used by providers, schools, hospitals 
and community partners. Applies in home, school, community, day programs, short-stay and 
health interfaces. 
 
Part 1  -  Crosswalk (one-page template) 
Header: Practice note name • Version/date • Source/owner • Applies to (people/settings) 
A) Triggers (when to use this note) 
• (List 3-6 short triggers) 
B) Do / Never do (top actions) 
• Do: 1) … 2) … 3) … 4) … 5) … 
• Never do: 1) … 2) … 3) … 
C) What to complete (forms & artefacts) 
• (name the exact templates from Appendix AA, e.g., “Easy Read: If I’m upset”, “72-Hour 
Review pack”, “R&W one-pager”) 
D) Who owns what (R/A/C/I) 
• A: role/title • R: team/role • C: roles (e.g., family, school, ACCO) • I: roles 
E) Measures (how we know it worked) 

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• Tile/KPI codes (from Appx S), e.g., sessions_out_home_median, mis_compliance_pct, 
interp_fulfilment_pct 
F) Standard links (exact clauses/appendices) 
• (bulleted references to the governing sections and appendices) 
G) Privacy & consent notes 
• (short DPIA/consent rules, interpreters/AAC, small-cell warning if publishing) 
(This one-pager sits on top. The detailed line-by-line mapping is below.) 
 
 
Part 2  -  Section-by-section mapping (table) 
Practice-note 
section / line 
“In-force” action or rule 
(plain) 
Standard/Appendix 
link 
What changes 
in practice 
(today) 
Owner Due 
e.g., “Early 
signs & de-
escalation” 
Use person’s exact 
calming phrase; try green 
→ amber supports before 
any restraint 
Safety & Restrictive 
Practices; Appx A/B/C 
Add phrase to 
Easy Read: If 
I’m upset; 
coach new staff 
this week 
IDC Lead 7 
days 
“Interpreter 
for plan 
reviews” 
Offer interpreter/Auslan 
for all reviews 
Appx N; Choice & 
Control 
Add booking 
rule to calendar 
template 
Coordinator 3 
days 
… … … … … … 
 
Part 3  -  Worked crosswalk: “Thriving Kids” (example, copy-ready) 
Header: Thriving Kids  -  Participation & Family Partnership Guide • v1.0 • Source: Practice 
• Applies to: children/young people (home/school/community/health) 
A) Triggers 
• Starting school or changing school/teacher/therapy. 
• New diagnosis or big routine change (move house, new sibling, short-stay). 
• Regular distress after school or on Sundays. 
• Plan review, complaint, or decline in participation. 
B) Do / Never do 
 
Do 
1. Build a Weekly Community & School Rhythm (Appx L) with the young person and 
family; include one new role to try each fortnight. 
2. Set up Communication Access every meeting (yes/no, AAC, interpreters/Auslan) 
(Appx N). 

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3. Use an If I’m upset Easy Read page (Appx K) at home and school; share the same 
calming phrase. 
4. Book 72-Hour Review after any serious incident; update the Fade Plan (Appx B-C). 
5. Agree a Team-around-the-Child contact list (school, family, provider, health) with 
response times. 
Never do 
1. Proceed with a plan change if the child/young person did not understand in their 
way (no access = no consent). 
2. Use restraint except emergency-only and always time-kept (Appx A). 
3. Share photos/data without recorded consent (Appx R). 
4. Let cancellations pile up - use backup plans (Appx L) and log why. 
5. Use family as interpreters for serious matters (unless an emergency; then replace 
ASAP) (Appx N). 
C) What to complete 
• Plain English Plan + Easy Read one-pagers (Appx K). 
• Weekly schedule & participation tracker (Appx L). 
• Interpreter/Auslan booking & session record (Appx N). 
• 72-Hour Review + Fade Plan (Appx B-C). 
• R&W one-pager if a contested decision is made (Appx H-J). 
D) Who owns what (R/A/C/I) 
• A: Coordinator (Children & Families) 
• R: IDC Lead / Key Worker (home & community) 
• C: Family/Carer; School contact; Therapist(s); Cultural broker/ACCO 
• I: Manager; Governance; GP/Paediatric team (when relevant) 
E) Measures 
• sessions_out_home_median ↑; variety_index_month ↑; role depth share at member+ ↑ (Appx 
S) 
• interp_fulfilment_pct ≥ target; 72h_review_on_time_pct ≥ target 
• Complaints resolved inside standard; restraints ↓ quarter-on-quarter 
F) Standard links 
• Choice & Control; Safety & Restrictive Practices; Communication Access (Appx N); 
Accessible Plan Pack (Appx K); Weekly Schedule (Appx L); 72-Hour Review & 
Fade Plan (Appx B-C); DPIA (Appx R); Owner Matrix (Appx Y). 
G) Privacy & consent 
• Record consent mode (tap/PIN/biometric/verbal-witnessed/alt-comm). 
• School/health info-sharing on a “minimum necessary” basis; small-cell suppression in 
any publication (Appx S). 

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Section-by-section mapping (Thriving Kids) 
Practice-note 
line 
Action in plain 
English 
Standard 
link Practice change now Owner Due 
“One page about 
me” 
Use About me + How 
to talk with me pages Appx K Create/update both 
pages; send to school Coordinator 5 days 
“Weekly 
community role” 
Plan real places/roles 
with transport Appx L Add venue, ally, backup; 
print fridge copy IDC Lead 3 days 
“After-incident 
meeting” 
Review within 72h; 
update Fade Plan Appx B-C Book review before close 
of next business day Manager 1 day 
“Interpreter 
when needed” 
Offer every time; 
record fulfilment Appx N Add “offer & record” 
step to school meetings Coordinator 3 days 
“Family 
partnership” 
Shared contact list with 
response times Appx Y Publish list in pack; 
confirm on Fridays Team weekly 
 
Part 4  -  Other crosswalks to complete (stubs) 
• ED/Health Interface Note → Handover & Medication Reconciliation; 
Communication Access; DPIA; Owner Matrix. 
• Mealtime & IDDSI Note → Safety & Restrictive Practices; OSCE First Response; 
Owner Matrix (stop-rule). 
• Switching Schools/Providers → Switching Protocol; Weekly Schedule stand-up; 
Evaluation Access (student records). 
• Transport & Community Safety → Participation; DPIA (location data); Red-Team 
scenario on failover. 
(Use the same one-page template + mapping table.) 
 
 
Part 5  -  Use this to route children/families quickly and safely 
Columns: Who presents → Where they land (service lane) → Who holds risk 
(accountable owner until handover completes) → Time standard (max elapsed) → 
Evidence sent (minimum pack) → Dashboard metric (publish de-identified). 
Who presents Where they land Who holds 
risk Time standard Evidence sent Dashboard 
metric 
0-8 yrs, mild-
moderate 
developmental 
delay or autism 
(no crisis) 
Thriving Kids 
mainstream early-
supports hub 
(MCH/GP/ECE/schoo
l gateway) 
Hub team lead 
(intake 
navigator) 
First contact ≤5 
days; first session 
≤21 days 
Intake form, 
parent goals, 
communication 
snapshot, 
consent 
Wait to first 
contact; wait to 
first session; % 
consented care 
plans 
0-8 yrs, 
permanent & 
significant 
disability likely 
NDIS access pathway 
+ IDC clinic warm 
handover 
IDC clinic 
lead (until 
NDIS access 
decision) 
Handover started 
≤2 days; 
completed ≤10 
days 
Common 
referral, 
preliminary 
functional 
summary, risks, 
interim supports 
Boundary SLA 
compliance; % 
accepted to 
NDIS; time to 
access decision 
0-8 yrs, no 
diagnosis yet, 
functional 
concerns 
Thriving Kids pre-
diagnosis skills 
stream 
(sleep/feeding/commu
nication/behaviour 
coaching) 
Stream 
coordinator Start ≤14 days 
Brief functional 
screen; family 
priorities; 
coaching plan 
Starts within 14 
days; % 
coaching goals 
met; escalation 
rate 

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9-17 yrs, 
learning/behavio
ur/participation 
needs 
School-Age 
Navigation & 
Supports (IDC-led 
community clinic + 
school interface) 
Clinic 
coordinator 
First contact ≤7 
days; first session 
≤28 days 
School referral, 
attendance 
record, 
communication/
AAC profile 
Waits; school 
attendance 
delta; CPI 
(school-age) 
Existing NDIS 
child (any age) 
also needing 
mainstream 
supports 
Shared-care protocol 
(IDC clinic ↔ 
GP/ECE/school) 
IDC clinic 
lead (for 
shared items) 
Shared plan 
agreed ≤10 days 
Shared support 
plan; service 
map; review 
dates 
Shared plan 
rate; reviews on 
time; 
duplicate/contra
diction rate 
ED presentation 
for 
behaviour/distre
ss (no major 
injury) 
IDC on-call advice + 
crisis de-escalation; 
schedule IDC clinic 
follow-up 
ED senior 
nurse (until 
discharge), 
then IDC 
clinic 
Safety plan 
before discharge; 
follow-up ≤24-72 
h 
ED summary, 
safety plan, 
seizure/meds 
review, contacts 
% with plan at 
discharge; 
follow-up 
within 72 h; 
repeat ED 30/90 
d 
ED presentation 
with aspiration 
risk/mealtime 
incident 
Mealtime/dysphagia 
pathway (IDC 
SLP/OT + GP) 
ED senior 
nurse → IDC 
mealtime lead 
at discharge 
Mealtime plan 
before discharge; 
community 
review ≤7 days 
IDDSI level, 
aspiration risks, 
posture/positioni
ng, choking 
history 
IDDSI plan at 
discharge; 
readmit ≤30 d; 
IDDSI drill pass 
rate 
Ambulance/poli
ce call-out 
(community 
crisis) 
Least-Restrictive 
Response + 72-hour 
multi-agency review 
On-scene lead 
(shift) → 
review chair 
(IDC/police/h
ealth) 
Review convened 
≤72 h 
Incident 
timeline, de-
escalation 
attempts, meds 
used, witnesses 
Restraint/sedati
on minutes; 72-
h review 
completion; 
corrective 
actions 
Discharged from 
hospital (any 
cause) 
30-day continuity 
pack + IDC clinic 
Ward 
discharge 
planner (until 
pack sent) → 
IDC clinic 
Pack issued at 
discharge; 
community 
review ≤7 days 
Meds 
reconciliation, 
mealtime & 
seizure 
protocols, 
contacts 
Pack 
completeness; 
7-day review 
rate; readmit 
≤30 d 
Child in Out-of-
Home Care 
(OOHC) with 
functional needs 
IDC clinic + OOHC 
health pathway + 
school 
Child Safety 
health 
coordinator 
First case 
conference ≤14 
days 
Care & 
Communication 
Passport, trauma 
notes, consents 
Conference on 
time; placement 
stability; school 
attendance 
First Nations 
family (any 
need) 
Place-based outreach 
via ACCHO with IDC 
support 
ACCHO 
coordinator 
First contact ≤5 
days; visit ≤14 
days 
Culturally 
adapted intake; 
interpreter if 
required 
Coverage by 
postcode; 
uptake; 
satisfaction 
score 
CALD family 
needing 
interpreter 
IDC clinic with 
interpreter + 
translated materials 
IDC intake 
navigator 
First contact ≤5 
days; interpreter 
booked ≤10 days 
Translated 
consent; 
interpreter 
booking; plain-
language plan 
Interpreter 
utilisation; plan 
comprehension 
score 
Rural/remote 
family 
Mobile clinic / 
telehealth + local 
GP/pharmacy hooks 
Mobile clinic 
lead 
First contact ≤5 
days; first session 
≤21 days 
Telehealth 
consent; 
device/test call 
log 
Telehealth 
completion; 
travel saved; 
outcomes parity 
index 
School flags risk 
of 
exclusion/expuls
ion 
IDC-school rapid 
response panel 
School 
principal 
(until panel 
meets) 
Panel ≤5 days; 
plan enacted ≤10 
days 
Behaviour data; 
triggers/ABC; 
adjustments 
tried; family 
view 
Exclusion 
avoided %; 
attendance 
delta; restraint 
incidents 
GP detects 
developmental 
concerns 
GP → Thriving Kids 
triage (warm 
handover) 
Thriving Kids 
triage nurse 
Handover started 
same day; booked 
≤14 days 
GP letter; Red 
Flags checklist; 
parent 
questionnaire 
GP referrals 
completed; time 
to first session 
Maternal & 
Child Health 
(MCH) nurse 
flags delay 
MCH → Thriving 
Kids (as above) 
MCH nurse 
(until booked) 
Booking made 
during visit; 
session ≤21 days 
MCH 
milestones; 
observations; 
parent goals 
Booking at 
point-of-care %; 
session within 
21 d 

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Allied health 
waitlist > 90 
days 
IDC clinic interim 
support + escalation 
IDC clinic 
coordinator 
Contact ≤5 days; 
interim session 
≤21 days 
Interim plan; 
risks; coaching 
leaflets 
Interim uptake; 
waitlist-to-
service 
conversion 
Dental/vision/he
aring unmet 
need 
Priority allied 
pathways (public 
dental; audiology; 
optometry) 
IDC navigator 
(until 
appointment) 
Booking ≤10 
days; visit ≤30 
days 
Referral; 
communication 
needs; consent 
Appointment 
within 30 d; 
treatment 
started 
Family 
distress/carer 
burnout 
Short-break & 
coaching, not ED 
Short-break 
coordinator 
Offer ≤48 h; start 
≤7 days 
Carer strain 
score; respite 
plan 
Respite started 
within 7 d; ED 
diversion rate 
Domestic/family 
violence risk 
DFV referral + safety 
plan + IDC clinic 
DFV service 
lead (safety), 
IDC clinic 
(health/partici
pation) 
Contact same 
day; plan ≤72 h 
Safety plan; 
contacts; code 
words; consent 
Same-day 
contact; re-
victimisation 
rate 
Housing 
insecurity 
Housing/homelessnes
s service + IDC 
support 
Housing case 
lead 
Contact ≤5 days; 
plan ≤14 days 
Evidence of 
need; support 
letter; risk 
summary 
Application 
lodged; 
placement 
within 30/90 d 
Transition 8→9 
yrs (ageing out 
of Thriving 
Kids) 
School-Age 
Navigation & 
Supports 
Clinic 
coordinator 
Transition plan 
started at 8½ yrs; 
active at 9 
Handover pack; 
current goals; 
risk plans 
On-time 
transition %; 
service gap days 
Transition 
17→18 yrs 
Youth-to-adult IDC 
pathway + NDIS (if 
eligible) 
IDC youth 
transition lead 
Plan ≤6 months 
before 18th; first 
adult contact ≤30 
days post-18 
Adult services 
map; GP 
handover; 
consent updates 
On-time 
transition %; 
post-18 gap 
days 
Crisis placement 
breakdown risk 
Rapid wrap-around 
(IDC, provider, 
housing, school) 
IDC crisis 
coordinator 
Plan ≤72 h; 
stabilise ≤14 days 
Crisis profile; 
triggers; 
staffing/safety 
plan 
Placement 
saved %; 
restraint 
minutes; ED 
diversions 
Thriving Kids 
intake rejects 
(outside scope) 
“No Wrong Door” 
handover to 
IDC/NDIS/other 
Refusing 
service must 
hand over 
Handover started 
same day; 
completed ≤10 
days 
Triage notes; 
referral form; 
contacts 
No-Wrong-
Door 
compliance; 
bounced 
referrals 
Island/remote 
community with 
limited transport 
Mobile clinic + 
telehealth + local 
GP/pharmacy hooks 
Mobile clinic 
lead 
First contact ≤5 
days; first session 
≤21 days 
Telehealth 
consent; 
device/test call 
log; connector 
details 
Telehealth 
completion; 
travel saved; 
outcomes parity 
index 
 
Implementation notes (for the practice note) 
• Time standards are maximums; sooner is better. Where two owners are listed, 
responsibility transfers only when the receiving service acknowledges handover. 
• Evidence sent are minimum items; add clinical documents when relevant (IDDSI plan, 
seizure protocol, medicines reconciliation, Care & Communication Passport). 
• Dashboard metrics are de-identified and published quarterly; each row should map to a 
public indicator (access, safety, participation, boundary SLAs). 
• Escalation: Missed time standards escalate automatically to a named senior and appear on 
the next dashboard. 
• Equity lens: All rows must be reportable by postcode, First Nations status, 
CALD/interpreter use and rurality to catch structural gaps. 
 

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What good looks like / Red flags 
Good: every practice note has a one-pager; tools are named; measures move; families and 
schools see the same pages; crosswalks get updated when notes change. 
Red flags: PDFs with nice words but no actions; plans that don’t show how to talk with the 
young person; restraint used because access failed; publication without suppression. 
 
Micro-scenarios (worked) 
• Prep to Year 7 transition: Crosswalk adds a school contact, bus route, and two new 
clubs. Interpreter booked for the parent. Participation variety rises; zero restraints in 
term 1. 
• Post-ED weekend: 72-hour review updates the If I’m upset page; Monday teacher 
uses the new calming phrase; no escalation and day completed. 
• New therapist joins: Given the one-pager; adds AAC vocabulary; weekly rhythm 
continues; family reports better handovers. 
 
Quick scripts 
• To a worker: “For this note, use the one-pager: when to use it, what to do, and which 
forms. If it isn’t in the crosswalk, it isn’t in force.” 
• To a school partner: “Here’s the one page and the two sheets we actually use. Same 
phrases, same contacts, same backup plan.” 
• To a family: “These pages are yours. If they stop matching real life, we fix them 
together.” 
 
Where to get help / Artefacts & Templates 
• Z1. Crosswalk one-page template (triggers; do/never; R/A/C/I; measures; links; 
privacy notes) 
• Z2. Section-by-section mapping table (CSV headers) 
• Z3. Thriving Kids crosswalk (filled example) 
• Z4. ED/Health, Mealtime/IDDSI, Switching crosswalk stubs 
• Z5. Provenance & review checklist (hash; six-monthly review) 
 
Summary companion. Decisions rely on the governing sections named in Choice & 
Control, Communication Access, Safety & Restrictive Practices, Participation/CPI, 
DPIA and Owner Matrix policies. 
 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 254 
 
Appendix AA  -  Service Template & Crosswalks Library (download pack 
index) 
Purpose 
Index of all operational crosswalks and templates supplied as a separately downloadable 
Service Crosswalk & Template Library.zip (Thriving Kids Crosswalk remains with 
Appendix Z.) 
How to use 
• Each item uses the appendix letter prefix (e.g., A-1, Y-2) + short name. 
• Narrative standards live in the main body / appendix; these artefacts operationalise 
them. 
• Owners/refresh cadence follow each appendix’s “Interfaces/Owner” lines. 
• Crosswalks and templates are designed as baseline minimum approaches, not the 
ceiling. 
• Due to parameters/limitations at URL repository, site may not display full listings.  
However, all files do present upon completion of download.  
 
 
Crosswalks  -   the double A baseline standards 
 
• AA-C01  -  NDIS / Access Pathway (no-wrong-door, warm handover) 
• AA-C02  -  Health Interfaces (GP / ED / Dental / Pharmacy) 
• AA-C03  -  Justice (police / courts / corrections / release) 
• AA-C04  -  Equity (First Nations, CALD/Auslan, AAC) 
• AA-C05  -  Out-of-Home Care & Child Adolescent and Adult Protection (with Court 
Decisions) 
• AA-C06  -  Family & DV 
• AA-C07  -  Housing & Homelessness 
• AA-C08  -  Ambulance & First Responder 
• AA-C09  -  Emergency Department (specific) 
• AA-C10  -  Mealtime / IDDSI 
• AA-C11  -  Switching Between Service Providers 
• AA-C12  -  Police & Custody Interface (hooks to AN- Templates) 
• AA-C13  -  Mental-Health Triage & Crisis Co-response 
• AA-C14  -  Outpatients / Planned-Care Handover 
• AA-C15  -  Inpatient Admission & Discharge Bridge 
• AA-C16  -  Residential & Day-Program Mealtime Readiness (site-level) 
• AA-C17  -  School / Education Interface 
• AA-C18  -  GP & Primary-Care (specific) 
• AA-C19  -  Transport & Travel (links to AE- Templates) 
• AA-C20  -  First Nations Partnership Crosswalk (O- Templates hooks) 
• AA-C21  -  Interpreter / Auslan / AAC Operations (N- Templates) 
• AA-C22  -  Privacy / DPIA & Publication Hooks (R- Templates ↔ S-8) 
• AA-C23  -  Red-Team & Incident Learning Loop (U- Templates) 
• AA-C24  -  Switching: Justice / Housing Variant 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 255 
 
• AA-C25  -  Psychotropic Stewardship in Community (AB- Templates) 
• AA-C26  -  Dental Desensitisation Pathway (AC- Templates) 
• AA-C27  -  Financial Safety (AH- Templates interface) 
• AA-C28  -  Research & Evaluation Access (W- Templates) 
• AA-C29  -  Tele-OSCE & Rural Micro-Hub (P- Templates) 
• AA-C30  -  IDC Curriculum Interfaces (Q- Templates) 
• AA-C31  -  Owner Matrix & Escalation (Y- Templates bridge) 
• AA-C32  -  Publication & Dashboard Release (AL/S-Templates) 
• AA-C33  -  Rural Telehealth & Mobile Clinic 
 
 
Templates  -  grouped by Appendix 
 
 
A  -  Safety & Restrictive Practices 
• A-1 Restrictive-Practice Log 
• A-2 Incident Report 
• A-3 Use-of-Force/Seclusion Timekeeping Log (custody variant) 
• A-4 Dignity-of-Risk: Community Risk/Opportunity Assessment 
• A-5 Debrief Prompts (room copy) 
B  -  72-Hour Review 
• B-1 72-Hour Learning Review  -  One-Page Summary 
• B-2 Fade Plan  -  One-Page Template 
• B-3 Chair’s Checklist (before/during/after) 
• B-4 Action Register (30/60/90-day check-backs) 
• B-5 Plain-Language Summary Handout 
C  -  Fade Plan Template (Restraint-Reduction & Positive Supports) 
• C-1 Behaviour & Trigger Profile (ABC patterns; sensory/contexts; early cues) 
• C-2 Hypothesis & Function Worksheet (SEAT; competing hypotheses; evidence 
needed) 
• C-3 Gentle Practices Ladder (from least-intrusive → more structured; “try first” 
list) 
• C-4 Environmental Adjustments Plan (noise, light, space, timing, predictability) 
• C-5 Communication & Accessibility Plan (plain/Easy Read, visuals, AAC, 
Auslan/interpreter) 
• C-6 Skill-Building Goals & Supports (replacement skills; micro-steps; prompting) 
• C-7 PRN Gate & Safeguards Insert (indications; non-drug first; dose/interval; 
review) 
• C-8 Positive Engagement Menu (interests, routines, community roles; “what helps”) 
• C-9 De-escalation Kit Checklist (tools, phrases, roles, space setup; “who does 
what”) 
• C-10 Fade Steps & Timetable (stepwise reductions; owners; dates; fallback rules) 
• C-11 Monitoring Data Sheet (frequency/intensity/duration; ABC notes; daily tiles) 
• C-12 Weekly Review Huddle Card (what changed/why; blockers; next step; dates) 
• C-13 Risk & Safeguards Map (Tier-0 triggers; emergency plan; consent & 
notifications) 
• C-14 Family/Supporter Partnership Sheet (roles; preferred phrases; 
home/community linkage) 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 256 
 
• C-15 Interface Handovers (ED, GP, school, justice) (what to send; plain-language 
companion) 
• C-16 72-Hour Insert Hook (links to B-1/B-2; how to update after an RP/incident) 
• C-17 Chair/Clinician Sign-off & Attestation (least-restrictive first; rationale in plain 
English) 
• C-18 Outcome Tiles & Thresholds (target behaviours, RP minutes, participation; 
success bands) 
• C-19 Audit & Change Notes (what we tried; what worked; version/date; steward) 
• C-20 Plain-Language Fade Summary (≤1 page for the person/family; next review 
date) 
D  -  Handover & Medication 
• D-1 Standard Handover Sheet (all settings) 
• D-2 Medication Reconciliation Checklist (72-hour) 
• D-3 ED Arrival Handover + ED Discharge Summary (plain companion) 
• D-4 GP Hand-Back Form (changes/indications/review dates) 
• D-5 Health Passport (conditions, allergies, contacts, communication) 
• D-6 Allergy & Adverse Reaction Card (wallet size) 
E  -  E-Receipts (minimum two-party) 
• E-1 UI Copy Deck (plain English/AAC screens) 
• E-2 Resolution Note Template (mandatory fields) 
F  -  Roster↔Claim Cross-Checks & Exceptions 
• F-1 Courtesy-Check Flow (states, SLAs, escalation) 
• F-2 Roster↔Claim Cross-Check Rules (minimal set) 
• F-3 Exception Codes List (E-series; maintained centrally) 
• F-4 Family View Explainer (what appears, correction path) 
• F-5 Rule Table (with policy tolerances) 
• F-6 Exceptions Queue Workflow (kanban + SLAs) 
• F-7 Courtesy-Check Script Pack 
• F-8 Finance Hold/Release Checklist 
G  -  Sanctions Ladder (governance) 
• G-1 Notice of Concern 
• G-2 Corrective Action Plan (CAP) 
• G-3 Payment-Hold Notice (categories, dates, release) 
• G-4 Probation/Suspension Decision Record 
• G-5 Right-of-Reply / Appeal Form 
• G-6 Publication Panel Content (public page fields) 
• G-7 Provider Right-of-Reply & Public Statement (sanctions) 
• G-8 Sanctions Publication Cover Letter 
H  -  Reasons & Weighting 
• H-1 R&W One-Pager (Issues → Evidence → Matrix → Tests → Findings → 
Actions) 
• H-2 Weights Rubric (0-4 cues & examples) 
• H-3 Plain-English Reasons Block (character-limited) 
• H-4 Contradiction Matrix (blank) 
• H-5 Principles One-Pager (short examples) 
• H-6 Confidence Rubric (High/Mod/Low) 
• H-7 Independent Verification Request 
I  -  Contradiction Matrix Templates 
• I-1 Contradiction Matrix (case-level, blank shell) 
• I-2 Evidence Line-Up Sheet (source → claim → test → reliability) 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 257 
 
• I-3 Competing Explanations Grid (A/B/C hypotheses with disconfirming facts) 
• I-4 Conflict Locator (where statements collide; who/when/context) 
• I-5 Resolution Notes & Rationale (why we prefer X over Y; rule refs) 
• I-6 Missing Pieces & Next-Inquiry Plan (what would change the view) 
• I-7 Blind Review Form (second reader: agree/partial/disagree + reasons) 
• I-8 Consistency Checks Pack (timeline, roles, documents, system logs) 
• I-9 Weight Shift Log (what changed weights; from→to; trigger/date) 
• I-10 Plain-English Contradiction Summary (≤200 words for H-1/J-1) 
• I-11 Publication Footnotes Builder (non-PII caveats; small-cell aware) 
• I-12 Version & Evidence Hash Register (tie to T-pack event IDs) 
J  -  Independent-Reasoning Certificate 
• J-1 IRC One-Page Form (fillable) 
• J-2 Second-Reviewer Checklist 
• J-3 Publication Decision Aid (what goes public; suppression rules) 
• J-4 Audit-Log Filing Checklist 
K  -  Accessible Plan Pack 
• K-1 Plain English Plan (2-4 pages) 
• K-2 Easy-Read One-Pagers set (My day; How to talk with me; Where I go; People & 
permissions; If I’m upset; My health basics; My rights; Photo & data sharing; 
Switching) 
• K-3 Consent & Attestation Form (accessible options) 
• K-4 Quarterly Update Checklist 
• K-5 Translation/Auslan/Audio Request Form 
• K-6 Supported Decision-Making & Consent Pack 
L  -  Weekly Community Schedule & Participation 
• L-1 Weekly Community Schedule (fillable) 
• L-2 Participation Tracker (individual/monthly) 
• L-3 Role-Depth Guide (observer/member/helper/paid) 
• L-4 Transport & Backup Planner (routes/contacts/contingencies) 
• L-5 Icon Set for Easy Read 
• L-6 Weekly Roster ↔ Community Schedule Bridge Sheet 
M  -  Switching Protocol 
• M-1 Switch Notice & Consent Form 
• M-2 Exit/Entry Data Set (JSON/CSV schema + human-readable PDF) 
• M-3 Two-Week Stand-Up Schedule (fillable) 
• M-4 Keys/Equipment Hand-Back Checklist 
• M-5 Continuity & Escalation Flowchart 
• M-6 Governance Notification & Payment-Hold (targeted) 
• M-7 Provider Transition Pack (expanded onboarding) 
• M-8 Release Continuity Pack  -  Court/Parole Variant 
• M-9 Switching Friction Report 
N  -  Interpreter/Auslan/AAC Toolkit 
• N-1 Interpreter/Auslan Booking & SLA + Quality Feedback 
• N-2 AAC Quick Set-Up Card (yes/no, core words, troubleshooting) 
• N-3 Teach-Back & Consent Checklist (attestation modes) 
• N-4 ED Communication Card (wallet/phone) 
• N-5 Session Record (offer/decline; interpreter IDs; start/stop) 
• N-6 Plain-Language Scripts (offer/decline/pre-brief/close-out) 
• N-7 Justice Fast-Path Booking (variant) 
O  -  First Nations Partnership 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 258 
 
• O-1 Partnership MoU (fillable) 
• O-2 Cultural Plan  -  person level (print + Easy Read) 
• O-3 Cultural Brokerage Booking & Payment 
• O-4 Interpreter Request (First Nations languages) 
• O-5 Cultural OSCE Rubric (worker competence) 
• O-6 Sorry Business Protocol & Schedule Change 
• O-7 Data-Sharing Consent (with revocation) 
P  -  Rural Micro-Hub & Tele-OSCE 
• P-1 Site & MoU Checklist 
• P-2 DPIA & Privacy Signage Set 
• P-3 Kit List & Setup Guide (network/power/cameras/AAC) 
• P-4 Weekly Timetable Poster + SMS Scripts 
• P-5 Tele-OSCE Proctor Checklist & Integrity Form 
• P-6 OSCE Station Packs & Scoring Rubrics 
• P-7 Result Letter + Remediation/Retake Plan 
• P-8 Diversion Referral to IDC/Micro-hub 
• P-9 Outreach & Examiner Pool Roster 
• P-10 Participation & Outreach Schedule 
Q  -  IDC Curriculum & Assessment 
• Q-1 Curriculum Map Poster + Module Outcomes 
• Q-2 EPA Logbook (fillable + CSV headers) 
• Q-3 Supervisor/Verifier Guide 
• Q-4 OSCE Station Packs & Rubrics 
• Q-5 Progression & Currency Checklist 
• Q-6 Scope Change & Remediation Form 
• Q-7 Audit & Publication Checklist (hashing/suppression) 
R  -  DPIA & Privacy (incl. AI) 
• R-1 DPIA Long-Form Template (fillable) 
• R-2 Plain-Language DPIA Summary (multi-language/Auslan) 
• R-3 Data Inventory Workbook (fields/retention/minimisation) 
• R-4 Risk Matrix & Controls Library 
• R-5 Publication Suppression Checklist 
• R-6 Third-Party Processor Register & DPA Checklist 
• R-7 Breach Response Playbook 
• R-8 Privacy Signage Pack (hubs/offices/apps) 
• R-9 AI Safety & Incident SOP (kill-switch; shadow-mode; rollback; audit-log 
schema) 
• R-10 AI Prompt Starter Pack (worked prompts for safe ops) 
• R-11 Executive Go/No-Go Checklist (privacy/DPIA/AI) 
S  -  Dashboards & Publication 
• S-1 Tile Specification Table (fields/denominators/windows/rounding) 
• S-2 Suppression Decision Tree (primary/secondary/complementary) 
• S-3 Release Checklist (validation → suppression → notes → sign-off → audit log) 
• S-4 Plain-English Glossary (labels & caveats) 
• S-5 Data-Correction Form (links to R&W/IRC) 
• S-6 Provenance Script (hashing & change-log pattern) 
• S-7 Small-Provider Data-Adapter Checklist 
• S-8 Publication Notes & Visible Change Log (per release/tile) 
• S-9 Year-1 KPI Tiles (national digest) 
T  -  Audit Log & Provenance 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 259 
 
• T-1 Audit Event Schema (JSON) with enumerated actions 
• T-2 Anchoring & Hashing Guide (Merkle root + publication pattern) 
• T-3 Provenance Export Format (bundle + hash manifest) 
• T-4 Access & Role Matrix (who can read what) 
• T-5 Query Cookbook (sample SQL/DSL) 
• T-6 Erasure Certificate Form & SOP 
• T-7 Privacy Guardrails (ip_hash, geo_coarse, no-PII diffs) 
• T-8 Event-Model Cheat-Sheet (standard API/webhook names) 
U  -  Red-Team 
• U-1 Rules-of-Engagement Pack (authorisation, hard stops, contacts) 
• U-2 Scenario Script Cards (A-F) 
• U-3 One-Page Report (S/E/R/F scoring) 
• U-4 CAP Tracker (owner/date/verification; dashboard feed) 
• U-5 Debrief Checklist (facts → why → fix → lesson) 
• U-6 Whistleblower & Anti-Retaliation Notice 
• U-7 Provenance & Hashing Script (attach to audit log) 
V  -  Peer Calibration & Quality 
• V-1 R&W/IRC Calibration Rubric (0-3 with critical fails) 
• V-2 Contradiction Matrix Mini-Rubric 
• V-3 OSCE Examiner Calibration Pack (station keys + marking guide) 
• V-4 RP-Log Spot-Check Sheet 
• V-5 Kappa/Agreement Calculator (spreadsheet) 
• V-6 Quality Summary One-Pager 
• V-7 Example Library (good/poor anonymised cases) 
W  -  Evaluation Access 
• W-1 Evaluation Access Request (purpose, tiers, DPIA, ethics, conflicts) 
• W-2 Consent Packs (Plain/Easy Read; interpreter/Auslan/AAC) 
• W-3 Data-Room User Agreement (no raw exports; suppression checks) 
• W-4 Participant Summary (≤2 pages; multi-language/Auslan/audio) 
• W-5 Sampling & Equity Checklist 
• W-6 Cultural Review Checklist (ACCO sign-off) 
• W-7 Provenance & Audit Checklist (hashes, event IDs) 
X  -  ROI & Assumptions 
• X-1 Assumptions Register (CSV + examples) 
• X-2 ROI Workbook Shell (inputs/formulas/sensitivity toggles) 
• X-3 One-Page ROI Summary (fillable) 
• X-4 Valuation Library (unit costs/tariffs; evidence strength) 
• X-5 Attribution Guide (stepped-wedge/DiD/red-team controls) 
• X-6 Double-Counting Checklist 
• X-7 Provenance & Filing Checklist 
Y  -  Owner Matrix & Escalation 
• Y-1 Owner Matrix (R/A/C/I) 
• Y-2 On-Call Roster & Handover Card (week grid; coverage; escalation; rural radio 
fallback) 
• Y-3 Escalation Decision Tree (S0-S3 triggers/timers) 
• Y-4 Close-Out Pack (MIS checklist + R&W one-pager + Publication Notes stub) 
• Y-5 Family/Partner Comms Scripts (S0/S1) 
• Y-6 Implementation Roadmap (0-90 / 91-180 / 181-365; swim-lanes & owners) 
• Y-7 Provider Self-Audit  -  Standards Readiness (lite) 
Z  -  Practice-Note Crosswalks 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 260 
 
• Z-1 Crosswalk One-Pager (triggers; do/never; RACI; measures; links; privacy notes) 
• Z-2 Section-by-Section Mapping (CSV headers) 
• Z-3 “Thriving Kids” Crosswalk (filled example) 
• Z-4 ED/Health, Mealtime/IDDSI, Switching Crosswalk Stubs 
• Z-5 Provenance & Review Checklist (hash; 6-monthly review) 
AB  -  Psychotropic Stewardship (Pharmacy) 
• AB-1 Start/Renew Checklist (indication, baseline measures, review dates) 
• AB-2 PRN Gate Card (indications, non-drug steps, dose/interval) 
• AB-3 Monitoring Log (effect/side-effects/time) 
• AB-4 Deprescribing Ladder & Taper Plan 
• AB-5 Service One-Pager (Plain English) 
• AB-6 72-Hour Review Insert (RP as PRN event) 
• AB-7 Medication Reconciliation Addendum (stewardship fields) 
• AB-8 Prescriber Letter Template (request review/change) 
AC  -  Dental Desensitisation 
• AC-1 Dental Desensitisation Passport 
• AC-2 Exposure Ladder & Data Sheet 
• AC-3 Visual Storyboard (clinic visit) 
• AC-4 Sensory Kit Checklist 
• AC-5 Appointment Day Plan 
• AC-6 After-Care & Pain/Red Flags Sheet 
• AC-7 Distress Insert (72-hour review companion) 
• AC-8 Consent & Recording Form (clinic copy) 
AD  -  Quiet Hours (Community MOU) 
• AD-1 Community “Quiet Hours” MOU 
• AD-2 Sensory Settings Checklist (venue self-audit) 
• AD-3 Queue Options & Booking Flow 
• AD-4 Pocket Card for Venue Staff 
• AD-5 Promotion Kit (poster/social copy/alt-text) 
• AD-6 Session Log & Feedback 
• AD-7 DPIA (Quiet Hours) Template 
• AD-8 First Nations Co-design Checklist 
AE  -  Transport 
• AE-1 Transport Pocket Card (pre-start checks) 
• AE-2 Vehicle Securement & Tie-Down Checklist 
• AE-3 Run Sheet (routes, stops, backup) 
• AE-4 Access Travel Card (plain words for the person) 
• AE-5 Incident Quick Form (transport) 
• AE-6 Subcontractor Brief & Acknowledgement 
• AE-7 Seating/Harness Risk Assessment 
• AE-8 Cultural & Interpreter Note for Transport 
AF  -  AT & AAC Procurement 
• AF-1 AT/AAC Assessment & Trial Request 
• AF-2 Trial Data Sheet & Outcomes 
• AF-3 DPIA Mini for AT/AAC 
• AF-4 Quote Bundle Checklist (value for money) 
• AF-5 Deployment & Training Plan 
• AF-6 Vocabulary Export & Backup Procedure 
• AF-7 Switching Exit Checklist for AT/AAC 
• AF-8 Service & Repair Log 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 261 
 
• AF-9 Low-Tech AAC Kit (printables) 
AG - Candour (Tribunal/OPA/Ombudsman) 
• AG-1A Plain-English Notice to the Person 
• AG-2A Decision Dossier Shell (Issues → R&W → Matrix → Tests → Orders & 
Safeguards) 
• AG-3A Safeguards Annex 
• AG-4A Service & Provenance Sheet (hashes + recipients) 
• AG-1 Hearing Fairness Protocol & Human-Factors Card 
• AG-2 OPA In-Person Visit & Conversation Record 
• AG-3 Counter-Evidence & Contradiction Duty 
• AG-4 Non-Mirroring Reasons & Independence Attestation 
• AG-5 Ombudsman Cover Page (timeliness & scope) 
• AG-6 Cross-Agency Routing & Ownership Matrix 
• AG-7 Post-Hearing Plain Summary (≤1 page, dated) 
• AG-8 Court Communication Passport & Adjustments Request 
• AG-9 Order Conditions  -  Easy-Read Summary (with safeguard checks) 
• AG-10 Authority & Representation Verification (conflicts/fit) 
• AG-11 Case Clock & Delay Escalation (public S-8 hook) 
• AG-12 Divergence Report (when we don’t mirror) 
AH  -  Financial Safety 
• AH-1 Money Agreement (Plain English + Easy Read) 
• AH-2 Spending Permissions Map (limits by role/item) 
• AH-3 Card & PIN Custody Register 
• AH-4 E-Receipt & Attestation Form 
• AH-5 Reimbursement & Cash-out SOP 
• AH-6 Red-Flag & Escalation Tree (S0-S3) 
• AH-7 Quarterly Family Summary Template 
• AH-8 Vendor Letter (receipt requirements & contact) 
• AH-9 Switching/Exit Financial Checklist 
• AH-10 Gifts/Benefits Register 
AI   -   Industrial Relations & Insurance 
• AI-1 Consultation Brief (change proposal) 
• AI-2 Staff & Union Cover Note (plain) 
• AI-3 Role & Scope Statement (IDC-linked) 
• AI-4 Investigation Terms of Reference & Witness Care 
• AI-5 Suspension/Stand-Down Letter (if used) 
• AI-6 Workers’ Compensation First Report 
• AI-7 Return-to-Work Plan Stub 
• AI-8 PI/PL Insurer Notice 
• AI-9 Motor Claim First Notice 
• AI-10 Cyber/Privacy Incident Notice 
• AI-11 Ombudsman Cover Page (with Candour pack link) 
• AI-12 Dispute Brief & Resolution Plan 
• AI-13 Evidence Bundle Index (R&W + Matrix + hashes) 
AJ  -  Research & Evaluation MoU 
• AJ-1 Partnership MoU (fillable) 
• AJ-2 Project Schedule (one-pager per study) 
• AJ-3 Consent Packs (Plain/Easy Read; interpreter/Auslan/AAC) 
• AJ-4 Data-Room User Agreement 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 262 
 
• AJ-5 Co-design & Governance Charter 
• AJ-6 Publication & IP Addendum 
• AJ-7 Plain-English Participant Summary Template 
• AJ-8 Provenance Checklist (hashes, audit IDs, retention & deletion) 
AK  -  Operational Prompt Pack 
• AK-1 Prompt Cards (OP-01…OP-14)  -  printable, two-sided 
• AK-2 Wall Posters  -  “Say • Check • Do • Record” 
• AK-3 QR Sheet  -  links to governing appendices 
• AK-4 Audit Sample Form  -  monthly prompt-use check 
• AK-5 Localisation Sheet  -  calming phrases, clinics, contacts 
• AK-6 Pocket App Pack  -  mobile-ready versions 
AL  -  Publication & Dashboard Schema (Public, Family, Provider) 
• AL-1 Channel Profiles (Public · Family · Provider  -  scope, fields, cadence) 
• AL-2 Data Dictionary (tile → field → type → unit → suppression) 
• AL-3 CSV/JSON Export Specs (delimiters, encodings, AU dates, headers) 
• AL-4 API Field Map & Versioning (v1/v2, deprecation rules, changelog) 
• AL-5 Suppression & Redaction Rules (public <5, rounding, small-cell logic) 
• AL-6 Tile Computation Sheets (formulas, denominators, QA notes) 
• AL-7 Accessibility & Presentation Guide (labels, units, alt text, colour safety) 
• AL-8 Privacy & DPIA Summary (purpose, minimisation, retention, lawful basis) 
• AL-9 Refresh & Release Runbook (quarterly jobs, timestamping, rollback) 
• AL-10 QA & Anomaly Checks (thresholds, drift, backfill, reconciliation) 
• AL-11 Family Portal Pack (plain-English field set, glossary, consent cues) 
• AL-12 Provider Portal Pack (role-based fields, error returns, support paths) 
• AL-13 Public Site Pack (static JSON, cache headers, sitemap/robots) 
• AL-14 Dashboard Embed Pack (iframes, tokens, rate limits, timeout UX) 
• AL-15 Governance & Contacts (owners, stewards, incident matrix, SLAs) 
AM  -  Public Narrative & Media 
• AM-1 Message House (one-pager) 
• AM-2 Press Statement Templates (routine; crisis holding; second update; close-out) 
• AM-3 Q&A Bank (restraint, privacy, participation, IDC workforce, finance safety) 
• AM-4 Social Copy & Alt-Text Guide 
• AM-5 Accessibility Checklist (language, captions, formats, interpreters/Auslan) 
• AM-6 First Nations Wording & Co-release Checklist 
• AM-7 Media Inquiry Log (deadline, ask, response, hash) 
• AM-8 Approval Matrix & Crisis Cadence Card 
• AM-9 Dashboard/Publication Suppression Check (Appx S) 
• AM-10 Lived-Experience Brief & Support Plan 
• AM-11 Correction & Retraction Protocol (visible change notes) 
• AM-12 Ministerial Reporting Pack (cadence + 2-page brief) 
AN  -  Police Integration, Corrections & Custody 
• AN-1 First-Minute Drill Card (laminated, two-sided) 
• AN-2 CAD Scripts & Fields (COMM_ACCESS_NEEDED, PREFER_YES_NO, 
etc.) 
• AN-3 Recruit Curriculum & OSCE Rubrics (hours & gates) 
• AN-4 Accessible Caution/Rights Script (Plain + Easy Read + Auslan link) 
• AN-5 Custody & Interview Access Checklist 
• AN-6 Patrol Scene Guides (traffic, shop, DV, missing, ED) 
• AN-7 72-Hour Review Pack (multi-agency template) 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 263 
 
• AN-8 Red-Team Scenario Builder (police variant) 
• AN-9 First Nations Co-response MoU Stub (with ACCO) 
• AN-10 Tele-OSCE Kit (rural coach workflow & checklist) 
• AN-11 Body-Worn Camera Handling & Privacy Note 
• AN-12 First-Response De-escalation Cue Card 
• AN-13 Custody Use-of-Force/Seclusion Timekeeping Log 
• AN-14 Vulnerable-Person Flag & Interview Support Plan 
• AN-15 Police Field Contact Note (Plain English + referral ticks) 
• AN-16 Certification & Currency Log (hours, OSCE, sign-off) 
• AN-17 Corrections & Custody Health Standard (summary) 
• AN-18 Academy Timetable Overlay (A4 printable) 
• AN-19 Custody Intake One-Pager (A4 printable) 
AO  -  IDC Equivalency & Bridging 
• AO-1 Equivalency Matrix (CSV)  -  title family → provisional band → bridges → 
assessments 
• AO-2 Individual Bridging Plan (auto-dated tasks + owners) 
• AO-3 RPL Evidence Checklist & Supervisor Attestation 
• AO-4 OSCE Booking Sheet & Results Log (mini/full; safety stations flagged) 
• AO-5 EPA Pack (INT, EVID, FF-VER, PRN, MEAL, HAND, CONS, PRIV, 
R&W/IRC, PUB, RURAL, SWITCH) 
• AO-6 Support Coordinator Decision-Quality Fast Pack 
• AO-6N Navigator Fast Bridge Pack  
• AO-7 SC Complaint-Independent Oversight Pack 
• AO-7N Navigator Oversight Pack  
• AO-8 Grand-parenting Letter (time-boxed equivalency with safety gates) 
• AO-8N Grandparenting Letter Navigator Transition  
• AO-9 Bench-Cards  -  Decision-Maker Fast Pack (R&W, Matrix, small-cell, applied 
tests) 
• AO-9N Bench-Cards for Navigators  
• AO-10 30/90-Day Review Form (gap close-out; status colours) 
• AO-11 Skill-Slip Red-Team Scenario Builder (trigger → scene → test → 
remediation) 
• AO-12 Title→Band Mapper (Quick Intake) (role → provisional band → pre-practice 
bridges) 
• AO-13 Governance OSCE (tile reading + actions; leaders/board) 
• AO-14 Annual Currency Tracker (OSCE/CPD due list; alerts) 
• AO-15 External Calibration Pack (double-marking sheets; kappa log) 
• AO-16 Rural & Paediatric Variant Kit (tele-OSCE, satellite hub checklist, paeds 
stations) 
• AO-17 Publication & S-8 Hook (how bridging artefacts surface as non-PII change 
notes) 
• AO-18 IDC Audit Plan (with risk-weighted sampling math) 
AO.1  -  DSC Equivalency & Bridging 
• AO.1-1 Role→Band Mapper (DSC) 
• AO.1-2 Bridging Plan (DSC) with rOSCE schedule 
• AO.1-3 rOSCE Rubrics (Triage, Interview, Weigh, Decision, Publish) 
• AO.1-4 EPA Pack (INT, EVID, FF-VER, PUB, RUN) 
• AO.1-5 Intake & Interview Checklists (access, privacy, First Nations wording) 
• AO.1-6 Calibration Kit (shared R&W case + scoring guide) 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 264 
 
• AO.1-7 Red-Team Scenario Builder (regulator edition) 
AO.2  -  Two-Key Guardianship 
• AO.2-1 Two-Key Pairing Request & Independence Screen 
• AO.2-2 Emergency Single-Key Authorisation & Risk Record 
• AO.2-3 72-Hour Review & Fade Plan 
• AO.2-4 Joint Decision Form (R&W summary + signatures) 
• AO.2-5 Contradiction Matrix  -  Two-Key Insert 
• AO.2-6 Independent Reasoning Certificate (IRC)  -  Co-sign/Dissent 
• AO.2-7 Registry Checklist  -  Service & Appeal-Ready Record 
• AO.2-8 IPP Assignment Log & SLA Tracker 
• AO.2-9 Cultural/Linguistic Fit & Accessibility Checklist (First Nations/Auslan/AAC) 
• AO.2-10 Family/Supporter Notice  -  Plain-English/Easy-Read (service of record) 
• AO.2-11 Quarterly Publication Pack (de-identified reasons + tiles index) 
• AO.2-12 Audit & Exceptions Report (emergency use; 72-hour compliance) 
AO.3  -  RPL Evidence Checklist 
• AO.3-1 RPL Evidence Checklist 
Note: additional AO.3 Templates to be workshopped and designed with governing bodies 
 
 
Pack metadata 
Filename: Service Crosswalk & Template Library (versioned, e.g., v1_DDMMYYYY). 
Structure: /Crosswalks/AA-C01…/ and /Templates/<AppendixPrefix>/<Code_Name>/. 
Licence: reuse permitted across the program; no resale; cite this white paper. 
Dates: documents use DD/MM/YYYY; filenames use DDMMYYYY. 
Owners: as per each appendix; CHANGELOG.md maintained in the library folder. 
 
Appendix AB  -  Pharmacy Psychotropic Stewardship Protocol 
Right medicine, clear purpose, minimum dose, time-limited, and reviewed with the person. 
Owner: Pharmacy & Clinical Governance 
Interfaces: Handover & Medication Reconciliation (Appx D); 72-Hour Learning Review & 
Fade Plan (Appx B-C); Safety & Restrictive Practices (Appx A); Interpreter/Auslan/AAC 
(Appx N); First Nations Partnership (Appx O); Workforce/OSCEs (Appx Q); Audit Log 
(Appx T); DPIA (Appx R); Dashboards & Suppression (Appx S); Switching Protocol (Appx 
M); Evaluation Access (Appx W). 
Why this matters (and why it hasn’t worked) 
Psychotropics are often used to “settle behaviour” instead of addressing pain, distress, or 
environment. Plans lack clear indications, PRN rules drift, reviews are late, and side-effects 
go unseen - leading to falls, weight gain, and rights breaches (chemical restraint). A 
stewardship protocol sets one safe method: define purpose, prove non-drug supports were 
tried, set dose/time limits, monitor effects, and taper when possible. 
Fast take (read this first) 

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• No purpose = no prescription. Write a plain goal (what changes and how we’ll 
know). 
• Access first: pain check, communication access (Appx N), environment fixes. 
• If used for behaviour control → it is a restrictive practice. Apply Appx A rules 
(authorisation, start/stop timing, review). 
• PRNs are specific: indication, first-line non-drug steps, max dose/24h, minimum re-
dose interval, stop by date. 
• Monitor & review: set dates up-front; track benefits/harms; taper when stable. 
• Record everything (two-party e-receipt + audit log); share a plain-English summary 
with the person/family. 
Scope 
All psychotropics (antipsychotics, benzodiazepines, sedating antihistamines, antidepressants 
used for agitation, mood stabilisers) in home, community, short-stay, day programs and 
health interfaces, including PRN and scheduled use. 
 
Definitions (plain) 
• Psychotropic: a medicine that affects mood, thinking or behaviour. 
• Chemical restraint: giving a medicine mainly to control behaviour, not to treat a 
diagnosed condition or clear, time-limited symptom - see Appx A rules. 
• PRN (“as needed”): only for the named indication with limits and alternatives tried 
first. 
 
Governing rules (use every time) 
1. Purpose & consent written first (plain words + access supports provided). 
2. Minimum effective dose for the shortest time. 
3. Document non-drug steps tried before PRN (and again next time). 
4. Monitoring plan set on day 1 (benefits and harms). 
5. Reviews on time (below); taper/stop unless clear benefit remains. 
6. Two-party attestation for timing when used as restraint. 
7. Reconcile within 72 hours on entry/switch (Appx D, Appx M). 
8. Cultural & language safety (Appx O, Appx N). 
9. Everything auditable (Appx T). 
 
Workflow (step-by-step) 
 
A) Before starting / renewing 
• Screen for causes: pain, infection, constipation, sleep, sensory overload, 
hunger/thirst, communication barriers. 
• Agree the purpose: “reduce night-time pacing from 6× to ≤2× per week” (example). 
• Record access supports: interpreter/Auslan/AAC set up; yes/no method. 
• Write the order clearly: medicine, dose range, indication, non-drug first steps, max 
dose/24h, re-dose interval, review & stop-by dates. 

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• Restrictive-practice check: if primary purpose is behaviour control → record 
authorisation, start/stop timing, emergency override steps (Appx A). 
• Risk screen: falls, dysphagia/aspiration, constipation, seizures, QT prolongation, 
interactions (alcohol/opiates). 
• Share the plain-English plan with the person/family. 
B) Each administration (including PRN) 
• Confirm indication is present and non-drug steps were tried/ruled out. 
• Record start time (and stop time if short-acting) and effect at 30-120 min. 
• Log adverse effects (oversedation, unsteady, EPS, paradoxical agitation). 
• If used as restraint: apply Appx A timing, notify per local rule, book 72-hour review. 
C) After any PRN use (same day) 
• Debrief briefly: what worked, what didn’t, what to try first next time. 
• If two PRNs within 24 h or ≥3/week → trigger prescriber/Pharmacist review. 
D) Scheduled reviews (minimum) 
• New start / dose change: 2 weeks, then 6-8 weeks. 
• Stable ongoing: every 12 weeks (or prescriber policy), with a taper test considered 
each review. 
• Post-incident/ED: within 72 hours (Appx B). 
Monitoring set (pick what fits the medicine & person) 
Domain Examples & frequency 
Effect on target agreed measure (e.g., pacing count; sleep hours; ABC log)  -  
daily/weekly 
Sedation/falls RASS or simple 0-3 scale; falls events  -  per shift 
Metabolic 
(antipsychotics) 
weight/BMI monthly x3 then q3-6m; BP; fasting glucose/lipids per 
policy 
Movement 
(EPS/Tardive) AIMS or brief EPS check each review; sooner if symptoms 
Constipation & swallow bowel chart daily; IDDSI/mealtime risks each review 
Cardiac risk QTc/EKG per policy & when risk factors present 
Cognition/affect simple checklist (alertness, engagement) weekly 
Record benefits and harms side-by-side; decisions must cite both. 
 
When is it chemical restraint vs therapeutic? (quick table) 
Situation Treat-ment (not RP) Chemical restraint (RP) 
Short-acting med for acute delirium with 
medical work-up 
✔ if treating delirium 
with diagnosis & plan 
✖ if used mainly to make 
someone “easier” 
Regular antipsychotic for psychosis with 
specialist oversight 
✔ with reviews & 
monitoring 
✖ if used for convenience 
without diagnosis/plan 

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Situation Treat-ment (not RP) Chemical restraint (RP) 
PRN given because noise/queue triggers 
distress and non-drug steps weren’t 
attempted 
 -  RP: log timing, 
authorisation, review 
 
 
Deprescribing / Fade plan (standard pattern) 
1. Confirm stability and non-drug supports in place. 
2. Agree taper steps (e.g., 25% dose cut every 2-4 weeks). 
3. Name watch-outs (withdrawal, rebound anxiety, insomnia). 
4. Add supports (sleep routine, sensory tools, pain plan). 
5. If relapse: step back one taper step; re-try later with extra supports. 
6. Stop date recorded; remove from repeat scripts if ceased. 
 
Safety stop-rules (act now, then review) 
• New confusion, over-sedation, or unsteady gait → hold next dose; seek clinical 
advice. 
• Suspected NMS/serotonin syndrome, severe EPS, allergic reaction → emergency 
pathway. 
• Two PRNs in 24 h or three in a week → urgent prescriber/pharmacist review. 
• Any choking/aspiration event → mealtime/IDDSI review (Appx Z crosswalk + 
Owner Matrix Y). 
 
Recording (minimum fields in chart/receipt) 
• Medicine, dose, route, batch (if relevant) 
• Indication present (yes/no) and non-drug steps attempted 
• Start time; effect (benefit/harms) at agreed interval 
• If RP: authorisation ID; start/stop times; notifier; 72-hour review booked 
• Who administered; two-party attestation (Appx E) 
• Any contact with prescriber/pharmacist and advice given 
 
Measures (internal; some publishable via tiles) 
• psychotropic_prn_rate_per_1000h (suppressed when small; Appx S) 
• review_on_time_pct (2-week / 6-8 week / 12-week) 
• taper_attempted_pct (eligible cases) & taper_success_90d_pct 
• oversedation_or_falls_after_dose_pct 
• rp_minutes_documented_pct (when PRN used for behaviour control) 
• Outcome pair: target behaviour ↓ with participation steady or ↑ (Appx L). 
 
Micro-scenarios (worked) 

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• Night agitation → pain + sleep fix (no PRN needed): Staff use the person’s yes/no 
card; pain gel and warm drink; lights dimmed. Agitation drops; no PRN; note added 
to plan. 
• PRN drift caught: Three PRNs in a week for queue distress. 72-hour review adds 
quiet waiting spot and headphones; prescriber halves PRN dose and narrows 
indication. Next month: PRN zero. 
• Deprescribing win: Stable for 3 months; taper 25% q2w with increased community 
outings; sleep routine added. Stopped at week 8; participation rises. 
 
Quick scripts 
• Explaining to a family: “Medicines that change mood or behaviour are last-line and 
time-limited. We start with comfort and communication first, and we review early and 
often.” 
• To a prescriber (referral): “Two PRNs in 24 h for noise-triggered distress despite 
headphones and calm space. Request review of PRN haloperidol 0.5 mg; propose 
narrower indication + taper plan.” 
• To staff: “If you can’t name the indication and the first non-drug step, you shouldn’t 
give the PRN.” 
 
Where to get help / Artefacts & Templates 
• AB-1 Psychotropic Start/Renew Form (purpose, access provided, risks, 
review/stop-by dates) 
• AB-2 PRN Card (indication, first-line non-drug steps, max dose/interval, stop-by 
date) 
• AB-3 Monitoring Pack (effect/harms side-by-side; sedation/falls/EPS/metabolic 
charts) 
• AB-4 Deprescribing Algorithm & Taper Tracker 
• AB-5 Plain-English Medicine Summary (family version; multi-language/Auslan) 
• AB-6 72-Hour Review insert (when PRN used as RP) 
• AB-7 Pharmacist 72-Hour Reconciliation Form (switching/entry) 
• AB-8 Prescriber Letter Template (concise data + request) 
 
Summary companion. Decisions rely on the governing sections named in Safety & 
Restrictive Practices, Handover & Medication Reconciliation, 72-Hour Review & Fade 
Plan, Communication Access, First Nations Partnership, DPIA, Audit Log and 
Dashboards. 
 
 
 

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Appendix AC  -  Dental Desensitisation Protocol 
Build tolerance, reduce fear, complete care without restraint. 
Owner: Oral Health (Dental Lead) 
Interfaces: Communication Access (Appx N); Accessible Plan Pack (Appx K); Weekly 
Schedule (Appx L); Handover & Medication Reconciliation (Appx D); 72-Hour Learning 
Review & Fade Plan (Appx B-C); Safety & Restrictive Practices (Appx A); First Nations 
Partnership (Appx O); Rural Micro-Hubs & Tele-OSCE (Appx P); DPIA (Appx R); Owner 
Matrix (Appx Y); Switching Protocol (Appx M). 
Why this matters (and why it hasn’t worked) 
People miss check-ups because clinics feel loud, bright and unpredictable. Visits start cold, 
communication access is missing, and teams jump to restraint or heavy sedation. Pain is 
missed, teeth are removed late, and trust drops. A graded, repeatable desensitisation plan 
with real access supports lets most people complete exams, cleans and simple treatment 
safely. 
Fast take (read this first) 
• Access first: interpreter/Auslan/AAC, yes/no method, plain words, teach-back. 
• Plan the ladder: short steps from “meet the space” → “open mouth 5-10 sec” → 
“clean with suction” → “local anaesthetic if needed”. 
• Rehearse at home/community; use photos, storyboards and the same calming phrase. 
• Measure small wins (seconds tolerated, tools touched) and build up; never force. 
• If medication or deep sedation is considered, get proper consent, follow clinical 
policy, and treat restraint rules as applicable (see Appx A). 
• Debrief within 72 hours after any distressed visit; update the plan. 
Scope 
All ages and settings (home practice, micro-hub pre-visits, community dental clinics, hospital 
dental). Applies to check-ups, clean/polish, X-rays, simple fillings, and pathwaying to 
specialist clinics when needed. 
 
Minimum safety & access rules 
1. Offer communication access every time (Appx N). 
2. Use visuals (photos of clinic/tools), sensory kit (sunglasses, headphones, weighted 
pad), and predictable order. 
3. Stop signals agreed beforehand (hand raise/thumb down or card). 
4. No restraint (physical or chemical) except emergency or planned under law with 
consent and timing (Appx A). 
5. Medication reconciliation before visits (Appx D)  -  note seizure meds, 
anticoagulants, allergies. 
6. Cultural protocols and family preferences (Appx O). 
7. Privacy for photos/videos used for rehearsal (DPIA, Appx R). 

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Desensitisation ladder (copy and tailor) 
Aim: complete an exam/clean without restraint; build to simple treatment. 
Level Step & success test Notes 
0 Story & kit at home: look at pictures; try 
sunglasses/headphones; hold mirror 
Use Easy Read storyboard; pick 
a calming phrase 
1 Front-of-clinic: enter, sit 2-3 min, leave on a win Schedule at quiet time; greet by 
name 
2 Room look-around: sit in chair (upright) 1-2 min; touch 
mirror; count to 10 Headphones on if needed 
3 Chair tilt & light: tilt slightly; light on with sunglasses; 10-
20 sec 
Say what’s next; practise 
breathing 
4 Mouth open: mirror in/out, 5-10 sec; stop signal honoured Reward immediately 
5 Suction sound & feel: touch lips/teeth 5-10 sec Show on hand first 
6 Toothbrush/polish tip: gentle vibration on a back tooth 10-
20 sec One quadrant only 
7 Full quick clean: 2-4 mins with breaks Timer visible; count-downs 
8 X-ray (if needed): practise bite-wing with cardboard, then 
quick capture Two-step coaching 
9 Local anaesthetic (if needed): numbing gel; count-down; 
hand squeeze 
Only with consent and clear 
purpose 
10 Simple filling/extraction pathway: if not tolerated → step 
back or plan specialist clinic No surprises; document reasons 
Move up only after 2-3 “green” successes at a level. Step back freely; celebrate micro-wins. 
 
Roles (R/A/C/I) 
• A: Dental Lead (clinic or commissioned dentist) 
• R: IDC Lead/Key Worker (home practice + visit coaching); Dental Assistant (in 
room) 
• C: Person/Representative; Family/Carer; Cultural broker/ACCO; GP/Allied health (if 
pain/feeding issues) 
• I: Manager; Governance/Privacy; School/day program (for practice carry-over) 
 
Visit recipe (15-40 minutes) 
Before the day (48-72 h) 
o Confirm supports (interpreter/Auslan/AAC). 
o Share 1-page plan (ladder level, calming phrase, stop signal, sensory kit). 
o Med reconciliation done; transport booked; short slot reserved (first/last of 
session). 
On the day 

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o Greet softly; match the plan; offer choice (music, sunglasses, who stands 
where). 
o State the order of steps; keep counts short; honour stop signals; log seconds 
tolerated. 
o If distress rises → step back one level; finish on a win. 
After 
o Reward; give plain-English after-care (brush/fluoride advice). 
o Record wins/barriers; schedule next step (≤2-4 weeks). 
o If there was distress, book 72-hour review and update the ladder. 
 
Pain & oral-health basics (build into the plan) 
• Pain first: check teeth, gums, ulcers; use simple pain scale (faces/FLACC via AAC). 
• Daily toothbrushing plan (smear/pea toothpaste, handle/grip options, visual timer). 
• Fluoride varnish and fissure sealants where indicated (consent recorded). 
• Food/drink swaps (limit frequent sugars/acid drinks); agree one small change at a 
time. 
• If feeding/swallow risks (IDDSI) → loop mealtime lead and speech pathology before 
treatment. 
 
Medication & sedation notes (high level) 
• Pre-visit anxiolytics or procedural sedation only with prescriber/dentist oversight, 
proper consent and monitoring. 
• If the primary purpose is behaviour control (not clinical treatment) → treat as 
restrictive practice and apply Appx A. 
• General anaesthesia / hospital pathway: consent + anaesthetist instructions (fasting 
etc.) + clear after-care and follow-up plan to continue desensitisation, not end it. 
 
Recording (minimum fields) 
• Ladder level targeted & level achieved; seconds tolerated for open-mouth/tools. 
• Access provided (interpreter/AAC), calming phrase used, stop-signal honoured (Y/N). 
• Sensory kit used; barriers (noise, smell, vibration). 
• Pain scale result; work done (exam/clean/X-ray/etc.). 
• Any medicine used (dose/route/indication); if RP → authorisation + start/stop times 
(Appx A). 
• Next step/date; who agreed; signatures/attestation. 
 
Measures (internal; some publishable) 
• Visit completion rate (exam/clean completed without restraint). 
• Ladder progress (highest level achieved this quarter). 
• Distress events requiring stop/step-back (count; downward trend). 

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• Sedation/GA rate (only where clinically indicated; publish with suppression rules, 
Appx S). 
• 72-hour review on time after distressed visits. 
• Home brushing adherence (weekly tick via Easy Read card). 
 
Micro-scenarios (worked) 
• Noise-sensitive adult: Starts at Level 2 with headphones and sunglasses; practises 
suction on hand; by Week 4 completes first clean without restraint. 
• Young person fearful of light: Social story + “count to 10” game; light turned on 
only after sunglasses on; chair tilt kept minimal. X-ray delayed; no meltdown. 
• Severe distress at Level 5: Team steps back to Level 3; books two short “look and 
leave” visits; adds lavender scent and weighted pad; returns to Level 5 the next week 
and succeeds. 
 
Quick scripts 
• To the person: “We’ll go in small steps. If you show this card, we stop and take a 
breather.” 
• To family: “We’re building up seconds in the chair. We’ll practise with the mirror at 
home and bring the same sunglasses.” 
• To the dentist: “Here’s the one-page plan: calming phrase, stop signal, current ladder 
level, and what we’re aiming to do today.” 
 
Where to get help / Artefacts & Templates 
• AC-1 Dental Passport (allergies, meds, access supports, calming phrase, stop signal) 
• AC-2 Desensitisation Ladder & Data Sheet (levels, seconds, notes, next step) 
• AC-3 Visual Storyboard & Photo Pack (clinic, tools, step order) 
• AC-4 Sensory Kit Checklist (sunglasses, headphones, pad, lip balm, scented wipe) 
• AC-5 Appointment Day Plan (who, when, quiet slot, success test) 
• AC-6 After-Care & Home Brushing Plan (plain English/Easy Read) 
• AC-7 Distress & 72-Hour Review Insert (for any difficult visit) 
• AC-8 Consent & Recording Pack (interpreters/Auslan/AAC, DPIA note for 
photos/videos) 
 
Summary companion. Decisions rely on the governing sections named in 
Communication Access, Safety & Restrictive Practices, Handover & Medication 
Reconciliation, 72-Hour Review & Fade Plan, First Nations Partnership, DPIA and 
Owner Matrix policies. 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 273 
 
 
Appendix AD  -  “Quiet Hours” Community MOU Template 
Make everyday places calmer and predictable so more people can join in. 
Owner: Community Partnerships & Participation 
Interfaces: Weekly Community Schedule & Participation (Appx L); Communication Access 
(Appx N); First Nations Partnership (Appx O); Dental & Health Access (Appx AC/D); Safety 
& Restrictive Practices (Appx A); Rural Micro-Hubs (Appx P); DPIA & Publication (Appx 
R/S); Audit Log (Appx T); Owner Matrix & Escalation (Appx Y); Evaluation Access (Appx 
W). 
Why this matters (and why it hasn’t worked) 
Shops, pools, cinemas and libraries can be loud, bright and unpredictable. People avoid them 
or have distress in queues. Staff want to help but don’t have a plan. A simple Quiet Hours 
MOU sets the time, the sensory settings and the roles - so visits are calmer, short, and 
successful. Participation goes up; incidents go down. 
Fast take (read this first) 
• Same slot every week (minimum 60 minutes) and published for a term/quarter. 
• Sensory settings agreed: lower lights, no PA/music, low-fragrance cleaning, visual 
clocks. 
• Queue alternatives: priority lane, take-a-number or pre-order/collect. 
• Trained staff on deck with a pocket card and a quick de-escalation script. 
• Communication access offered: plain signs, AAC picture cards; interpreters/Auslan 
by booking. 
• Small “quiet space” available to pause and regroup. 
• Measure it: sessions delivered, attendance, cancellations, short feedback, incidents (if 
any). 
Scope 
Supermarkets, libraries, pools/gyms, community centres, museums, cinemas, pharmacies, 
council service desks, transport offices, banks/post, and small-town venues via the micro-
hub. Works for children, adults and older people; co-designed with the local ACCO/cultural 
authority where relevant. 
 
Quiet Hours  -  MOU template (fillable) 
A. Parties & purpose 
Venue (name, contact) • Provider/Network (contact) • ACCO/cultural authority (if 
partnering). 
Purpose: provide a low-sensory, predictable hour each week so people can shop, swim, study, 
watch a film or use services safely. 
B. Days, times & capacity 

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• Day/time (e.g., Tuesdays 4-5 pm). 
• Blackout dates (public holidays, events). 
• Max capacity (if needed) and how it’s managed. 
C. Sensory settings (minimum) 
• Lights: set to agreed level (e.g., ~50% lux; no flashing displays). 
• Sound: no music/PA unless safety; alarms tested outside the hour where possible. 
• Smell: avoid strong floor polish/perfume; schedule cleaning before/after. 
• Visuals: simple signs; visual timer or countdown board. 
• Environment map: show entrances, quiet space, toilets, lift, low-traffic paths. 
D. Queue & service options 
• Priority checkout/desk; take-a-number system; seat while waiting. 
• Pre-order / click-and-collect spot. 
• “I need more time” card accepted without fuss. 
E. Staff roles & training 
• Quiet Hours Lead on site. 
• 30-minute briefing: calm greeting, one-step instructions, stop signal respect, offer of 
help, escalation path. 
• Pocket card (plain scripts + do/never do). 
F. Communication access & inclusion 
• Offer AAC picture card set; plain-language signs; interpreters/Auslan on request. 
• First Nations protocol: welcome signage; cultural broker contact if partnering. 
G. Safety & escalation 
• Local emergency plan (who calls; where to wait). 
• If distress rises: step to quiet space; offer water; call family/ally if requested; no 
restraint except emergency (Appx A). 
H. Data, privacy & evaluation 
• What is counted (sessions delivered, head-count range, short feedback). 
• No photos/videos without consent; any reporting follows suppression rules (Appx 
S). 
• File a one-page term summary with a provenance hash (Appx T). 
I. Money & support 
• Any small costs (staffing, signage, cleaning timing) and how covered; brokerage for 
ACCO involvement. 
J. Promotion & review 

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• How the slot is advertised (posters, website, social). 
• Quarterly review meeting (15 min): what worked, what to tweak. 
K. Signatures 
Venue manager • Provider lead • ACCO/cultural authority (if applicable) • Dates. 
 
Setup checklist (venue) 
• Posters up with day/time; website updated. 
• Lights/music/PA plan tested; alarms scheduled outside the hour. 
• Priority lane sign and seat in place. 
• Quiet space set (chairs, water, basic kit). 
• Staff pocket cards printed; lead on roster. 
• Environment map printed at entry. 
On-the-day flow (venue + provider) 
1. 5 min before: lights/sound set; lead does a calm walk-through. 
2. Start: greet at door; give “quiet hour welcome” card; point to map/quiet space. 
3. During: help quickly; keep instructions short; honour stop signals; avoid crowding. 
4. If distress: step to quiet space; reduce stimuli; call ally if asked. 
5. Finish: thank people; reset; note any issues in the log. 
 
Measures (internal; some publish) 
• Sessions delivered vs planned (%) 
• Attendance band (e.g., 0-5 / 6-15 / 16-30) 
• Cancellations/no-shows (count) & reasons 
• Short feedback (good / ok / needs work) with one open comment 
• Incidents (count; proportion resolved without police/ambulance) 
• Interpreter/AAC provided (%) when booked 
• Repeat participation (returned within 4 weeks) 
(Public numbers follow Appx S suppression & rounding.) 
 
Micro-scenarios (worked) 
• Supermarket: PA/muzak off; staff use “one-step, one-question” script; a customer 
uses priority checkout and a take-a-number ticket - visit done in 12 minutes, no 
distress. 
• Pool: Lifeguards use visual flags instead of whistles during the hour; a small quiet 
room offers a pause; three new swimmers complete two laps. 
• Library (remote town): Micro-hub sets a weekly hour with the library; lights 
dimmed; storytime with visual timetable; attendance grows from 3 to 12 over a term. 
• Cinema: Sunday 10am slot with low volume, captions on, and relaxed seating; 
families bring snacks; zero exits mid-film after adding a pre-visit storyboard. 

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Quick scripts (pocket card) 
• Welcome: “Hi, this is our quiet hour. Lights and music are low. Take your time - tell 
me if you’d like a quieter spot.” 
• Offer help: “Would a number ticket or a priority checkout help today?” 
• If distressed: “We can pause in the quiet space. Would you like someone called?” 
• To other customers: “This is our quiet hour - thanks for keeping noise low and 
giving people space.” 
 
Where to get help / Artefacts & Templates 
• AD-1 Quiet Hours MOU (fillable) 
• AD-2 Sensory Settings Checklist & Environment Map template 
• AD-3 Queue & Service Options pack (signage + number tickets) 
• AD-4 Staff Pocket Card (scripts: welcome, help, de-escalate) 
• AD-5 Promotion kit (poster, web copy, social tile) 
• AD-6 Session Log & Term Summary (with provenance hash) 
• AD-7 DPIA & Privacy note (no photos; suppression rules) 
• AD-8 First Nations co-design checklist & brokerage form 
 
Summary companion. Decisions rely on the governing sections named in 
Participation/CPI, Communication Access, Safety & Restrictive Practices, First Nations 
Partnership, DPIA/Publication and Owner Matrix policies. 
 
Appendix AE  -  Transport Staff Pocket Card 
Owner: Transport & Community Access 
Interfaces: Weekly Community Schedule & Participation (Appx L); Communication Access 
(Appx N); Safety & Restrictive Practices (Appx A); Handover & Medication Reconciliation 
(Appx D); Owner Matrix & Escalation (Appx Y); First Nations Partnership (Appx O); DPIA 
& Publication (Appx R/S); Audit Log (Appx T). 
Why this matters (and why it hasn’t worked) 
Trips fall over when pickups are vague, communication access is missing, or wheelchairs 
aren’t secured right. Distress rises in noise and traffic, and staff sometimes use makeshift 
restraints. This pocket card sets a clear, safe routine so people arrive calm and on time - 
without restrictive practices. 
Fast take (read this first) 
• Know the plan: who, where, when, access supports, and backups (Appx L/N). 
• Seatbelts are safety; any harness beyond vehicle safety is a restrictive practice 
(needs authorisation or emergency rule) (Appx A). 

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• Wheelchairs: 4-point tie-down + occupant belt, never to removable parts. 
• If distress: reduce stimuli, offer choices, don’t hold or tie; pull over safe and use de-
escalation script. 
• Record the basics (pickup/drop, issues, any incidents) and escalate per Owner Matrix 
(Appx Y). 
Scope 
All transport delivered or arranged by providers: vans, cars, taxis/rideshare, community 
buses, rural micro-hub shuttles. Applies to school, work, health, community and switching 
visits. 
 
Pocket Card  -  Side A (Before / During / After) 
1) Before you start (1-2 mins) 
• Check run sheet: names, addresses, access notes, mobility aid, stop-signal, emergency 
contacts. 
• Communication access ready: yes/no cards, AAC app/board; interpreter booked if needed 
(Appx N). 
• Vehicle quick check: fuel, tyres, ramp/lift, restraints set, first-aid kit, phone charged. 
2) Pickup (calm start) 
• Greet by name; plain words + visual (“Next: car → [place]”). 
• Confirm seat preference, headphones/sunglasses if helpful. 
• Wheelchair users: brakes on, 4-point tie-down to solid frame, lap-shoulder belt low across 
pelvis; no straps to wheels/armrests/trays. 
3) On the road 
• Drive smooth; one voice at a time; offer short choices (“music off/on?”, “window a little?”). 
• Watch early cues (fidget, fast breathing). Use calming phrase from plan. 
• If distress rises: 
1. Pull over safely, hazards on. 
2. Reduce noise/light; offer water; check pain/needs. 
3. Use yes/no/AAC to choose next step (pause/return/continue). 
4. If imminent danger only, follow emergency steps (Appx A) and time-keep. 
4) Health events (quick) 
• Seizure: stop safely; time it; protect head; recovery position when safe; call 000 if >5 min, 
repeat seizures, injury, or per plan. 
• Choking: stop; follow mealtime/IDDSI plan if eating in vehicle (generally avoid eating in 
transit). 
• Crash/near miss: keep everyone seated if safe; call emergency services; notify per playbook. 
5) Drop-off & after 
• Confirm destination staff/family receive the person. 
• Note any changes (mood, equipment issue, near miss). 
• Log incident or courtesy note if something may affect the next shift. 

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Pocket Card  -  Side B (Rules, Do / Never Do, Scripts) 
Safety & restraint rules (plain) 
• Seatbelt = required. 
• Harnesses/positioning aids only if part of an approved seating system or lawfully authorised 
plan. 
• Never tie with scarves/straps, hold someone down, or wedge with bags. 
• Ramps/lifts: secure vehicle; flat ground; spotter if needed; hands clear; brakes on before 
securing. 
Do / Never do 
Do: 
• Use the same calming phrase and stop-signal as in the plan. 
• Offer quiet options (music off, window slightly). 
• Call ahead if running late; use backup stop from the schedule. 
• Report loose restraints or equipment faults immediately. 
Never do: 
• Leave a person alone in a vehicle. 
• Share routes/photos on social media. 
• Move the vehicle while belts or tie-downs are off. 
• Use family as interpreters for serious matters (unless emergency, then replace ASAP). 
Quick scripts (plain) 
• Offer choice: “Would you like the music off or a little quieter?” 
• If anxious: “We can take a short pause or head straight there - your choice.” 
• If stopping: “I’m pulling over somewhere safe so we can slow things down.” 
• To bystanders: “We’re okay - thanks for giving us some space.” 
 
Recording (minimum fields) 
• Date/time; pickup & drop-off; people transported; access provided 
(AAC/interpreter); any pause/route change and why; wheelchair securement check 
(Y/N); incidents/near misses; who was informed and when. 
Measures (internal; some publishable) 
• On-time pickups/drops (%); zero-defect securement audits (%); incidents/near 
misses (rate per 10,000 km); distress stops that resolved without restraint (%); 
interpreter/AAC provided when flagged (%). 
Micro-scenarios (worked) 
• Noise spike on freeway: pull off at rest area; music off; window cracked; agree 
“straight to venue”; trip completes, note filed. 

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• Loose tray on wheelchair: stop; secure or remove tray; photo of mount (no person) 
filed to maintenance; run continues safely. 
• Taxi subcontract: driver given one-page plan (calming phrase, stop-signal, belt rule); 
AAC card supplied; successful school drop. 
 
Where to get help / Artefacts & Templates 
• AE-1 Pocket Card (print, two-sided) 
• AE-2 Vehicle Safety & Securement Checklist (daily) 
• AE-3 Run Sheet + Backup Stops (from Appx L) 
• AE-4 Communication Access travel card (yes/no, scripts) 
• AE-5 Incident / Near-Miss quick form (with audit-log link) 
• AE-6 Subcontractor briefing sheet (taxis/rideshare/community bus) 
• AE-7 Seating/Harness risk assessment (links to Appx A) 
• AE-8 Cultural & Interpreter booking note (Appx O/N) 
 
Summary companion. Decisions rely on the governing sections named in 
Participation/CPI, Communication Access, Safety & Restrictive Practices, Handover & 
Medication Reconciliation, First Nations Partnership, DPIA/Publication and Owner 
Matrix policies. 
 
Appendix AF  -  Assistive Technology (AT) & AAC Procurement Spec 
Right tool, right voice, owned by the person, safe by design. 
Owner: Procurement & Clinical Technology (with Speech Pathology/OT leads) 
Interfaces: Communication Access (Appx N); Accessible Plan Pack (Appx K); Weekly 
Schedule (Appx L); Safety & Restrictive Practices (Appx A); Handover & Medication 
Reconciliation (Appx D); First Nations Partnership (Appx O); Rural Micro-Hubs (Appx P); 
Workforce/OSCEs (Appx Q); DPIA & Publication (Appx R/S); Audit Log (Appx T); 
Switching Protocol (Appx M); Owner Matrix (Appx Y). 
Why this matters (and why it hasn’t worked) 
People lose their voice when devices are hard to get, locked to providers, or arrive without 
training. Purchases chase discounts, not fit. Data is synced to random clouds. When AT/AAC 
is person-owned, trialled, and supported, participation rises and restraint drops. This spec 
makes that the default. 
Fast take (read this first) 
• Assessment → trial → selection → training → review. No “buy first, figure out 
later.” 
• Licences and vocab belong to the person, not the provider. Switching must be easy 
(export/import). 

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• Offline first, privacy by design; no always-on recording; encrypted backups. 
• Access methods (touch, switch, eye gaze, keyguard, partner-assisted scanning) 
supported. 
• Spare pool + repair SLAs so the person is never without a voice. 
• Measure use and outcomes, not just purchases. 
Scope 
All AAC and related AT used for communication, planning and access (low-tech 
boards/books; mid/high-tech speech-generating devices; switches; mounts; robust tablets; 
hearing/vision add-ons where relevant). Applies to home, community, day programs, school, 
health, rural micro-hubs and during provider switching. 
 
Principles (plain) 
1. Person first: selection by goals and contexts; culturally safe language options. 
2. Own & carry: device, licence and vocabulary travel with the person. 
3. Try before buy: structured trials with clear success tests. 
4. Access everywhere: supports at home, in vehicles, in noisy places, and during health 
visits. 
5. Simple + durable: fewer steps; rugged; long battery; easy clean. 
6. Privacy/consent: minimum data; no covert capture; small-cell rules for any reporting. 
7. Support & training: staff/family pass the OSCE for AAC support (Appx Q). 
8. Switch-ready: export/import without fees; handover pack in Switching Protocol 
(Appx M). 
 
Procurement workflow (step-by-step) 
1. Referral & assessment (Speech Pathology/OT lead) 
o Goals (what the person wants to say/do), settings, partners, 
motor/vision/hearing, yes/no method. 
o First-language and First Nations language needs; interpreter/Auslan (Appx N, 
O). 
2. Trial plan (2-4 weeks each option) 
o Choose 1-2 candidate systems (low-tech + high-tech if relevant). 
o Define success tests (e.g., 3 novel messages/day at home & community; order 
own food; make a choice in health visit). 
o Provide mount/case and training for partners; collect simple use logs. 
3. Selection & DPIA 
o Compare trial data; complete short DPIA (Appx R) covering backups, cloud, 
MDM, permissions. 
o Confirm licence to the person, export format, and switching terms. 
4. Quote & purchase 
o Bundle: device + case + mount + charger + spare kit + licence + voices + 
warranty + training hours + support SLA. 
o Record provenance in audit log (Appx T). 
5. Deployment 

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o Load vocab; set voices (incl. child/First Nations language where available); 
configure offline use and backups. 
o Add to Accessible Plan Pack; publish quick “How to talk with me” page 
(Appx K). 
6. Training & OSCE 
o Partners (family, staff, peers) complete quick training; IDC staff complete 
OSCE-C (comm access) (Appx Q). 
o Provide scripts/cards for everyday places. 
7. Review & renewal 
o 6-8 week review against goals; adjust vocab/mounts; confirm repairs/loan 
process. 
o Annual check; renew licences; refresh training if staff change. 
 
Minimum technical spec (AAC/high-tech) 
• Hardware 
o Rugged case + shoulder/hand strap; drop rating or proven field durability. 
o Battery ≥ 8-10h real use; USB-C; spare charger; charging safety label. 
o Mounting: universal plate or clamp compatible 
(wheelchair/table/vehiclepassenger only). 
o I/O: switch ports or wireless switch; eye-gaze or camera access if needed; 
loud but clean speaker; headphone jack/Bluetooth. 
o Weight/size suited to the person; keyguard option. 
• Software 
o Symbol + text; quick phrases; message banking; bilingual layouts; custom 
key sizes. 
o Offline operation fully functional; cloud sync optional with consent. 
o Export/import vocab (open format or widely used standard). 
o Voices: adult/child; local accents; First Nations packs where available. 
o Privacy: no auto-upload media; per-app permissions; easy “privacy off” 
toggle. 
o Analytics: on-device counts (e.g., messages/day) viewable by the person; no 
personal analytics published. 
• Security/MDM 
o PIN/biometric; managed updates; remote-wipe only with dual authorisation; 
device labeled “Communication - medical equipment - do not confiscate.” 
 
Low-tech spec (must have in every plan) 
• Laminated core board (A4/A3); waterproof option; lanyard card for yes/no/stop/help. 
• Partner-assisted scanning template; spare copies in bag/vehicle. 
• Photo/symbol schedule strips for community visits; removable for privacy. 
 
Access methods & mounts (choose what fits) 
• Touch with keyguard • Switch scanning (1-2 switch) • Eye gaze • Head/motion • 
Partner scanning. 

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• Mounts: wheelchair (clinically approved), table, bed, vehicle passenger use only. 
Quick-release; no straps used as restraints (Appx A). 
 
Safety, privacy & lawfulness 
• No always-on audio/video. Recording only with consent + DPIA; short retention. 
• Respect search rules: staff may not dig through private messages/photos without 
lawful reason and consent. 
• Cleaning protocol compatible with device; avoid fluid ingress. 
• Label chargers/cables; avoid trip hazards; inspect mounts monthly. 
 
Support & service levels 
• Spare/loan pool: replacement within 2 business days (metro) / 5 days (remote). 
• Repair SLA: triage in 1 day; repair/replace ≤ 10 business days or provide extended 
loan. 
• Help desk hours and escalation path (Appx Y). 
• Training package: min 4 hours partner training at go-live; refresh at staff turnover. 
 
Switching & ownership (non-negotiables) 
• Person holds the licence, vocab files and mounts that fit their chair/desk. 
• Exit pack (Appx M): device, charger, mounts, export of vocab/settings, licence keys, 
warranty/support details. 
• No “factory reset” without a backup given to the person/representative. 
 
Do / Never do (quick) 
Do: trial first; set goals; train partners; keep low-tech backup; export vocab monthly; record 
consent modes. 
Never do: buy without trial; lock licence to a provider; remove a device as “punishment”; 
use straps to hold the person; enable cloud sync without consent. 
 
Recording (minimum fields) 
• Assessment summary; chosen device & access method; licences (owner & expiry); 
mounts; training delivered (who/when); backup method; consent settings; review 
dates; service/repair history; export hash for vocab backups (Appx T). 
 
Measures (internal; some publishable) 
• Time from referral → trial start / device in hand (days). 
• Partner OSCE-C pass rate (% in date). 

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• Daily use (messages/day or minutes with device)  -  person-level private; publish only 
aggregates. 
• Goal hits (e.g., orders own food weekly, starts 3 conversations/day). 
• Repair/loan timeliness; switching completeness (exit packs with exports, %). 
• Complaints about access resolved inside standard. 
 
Micro-scenarios (worked) 
• School & community: Trial board + app; success test = order at café and answer two 
teacher questions/day. App chosen; vocab exported monthly; teacher and parent pass 
OSCE-C. 
• Rural: Micro-hub loan kit; satellite updates off, offline backups to SD card; repair 
swap posted next-day. 
• Switching providers: Exit pack handed over with vocab export; new team imports in 
10 minutes; person’s phrases unchanged. 
 
Quick scripts 
• To a family: “We’ll try options first. The licence and vocabulary belong to you, and 
the device works without the internet.” 
• To staff: “If the person’s device is not present and on, we haven’t provided 
communication access.” 
• To vendor: “We require person-owned licences, offline operation, open export, and a 
10-day repair SLA.” 
 
Where to get help / Artefacts & Templates 
• AF-1 Assessment & Trial Plan (goals, contexts, success tests) 
• AF-2 Trial Data Sheet (use counts, partner notes, yes/no method) 
• AF-3 DPIA mini (cloud, backups, permissions, analytics) 
• AF-4 Quote & Bundle Checklist (device + case + mount + licence + SLA) 
• AF-5 Deployment & Training Checklist (setup, voices, partners trained, OSCE 
booked) 
• AF-6 Vocab Export/Backup SOP (with provenance hash) 
• AF-7 Switching Exit Pack (export, licences, mounts list) 
• AF-8 Service & Repair Log (SLA tracker) 
• AF-9 Low-Tech Kit Pack (core board, lanyard yes/no, scanning card) 
 
Summary companion. Decisions rely on the governing sections named in 
Communication Access, Participation/CPI, Safety & Restrictive Practices, Handover & 
Medication Reconciliation, First Nations Partnership, DPIA/Publication, Audit Log, 
Workforce/OSCEs and Switching policies. 

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Appendix AG  -  Tribunal/OPA/DSC “Candour by Template” Exemplars 
Say everything that matters, plainly, with evidence and safeguards attached. 
Owner: Governance & Legal Liaison & DSC Unit 
Interfaces: Reasons & Weighting (Appx H); Contradiction Matrix (Appx I); Independent-
Reasoning Certificate (Appx J); Owner Matrix & Escalation (Appx Y); Safety & Restrictive 
Practices (Appx A); 72-Hour Review & Fade Plan (Appx B-C); Communication Access 
(Appx N); First Nations Partnership (Appx O); DPIA & Publication (Appx R/S/AL); Audit 
Log (Appx T); Switching Protocol (Appx M); Navigator/Foundational Supports; AG.1 
(DSC/Ombudsman companion). 
 
Why this matters (and why it hasn’t worked) 
Bundles to Tribunal/OPA often arrive late, one-sided, and jargon-heavy. The person’s voice 
(and interpreter/Auslan/AAC supports) is missing; evidence isn’t weighed; contradictions 
aren’t resolved; safeguards lack expiry/fade. That slows hearings and risks over-restrictive 
orders. “Candour by template” fixes this: we show the helpful and unhelpful facts, number 
and weight evidence, resolve contradictions, and attach time-bounded safeguards, with 
privacy and provenance you can check. 
 
Fast take (read this first) 
• Use one standard pack with four parts (below). 
• Candour rule: include facts that help and facts that hurt; explain the weight (0-4). 
• Access first: interpreter/Auslan/AAC offered and recorded; the person’s will & 
preferences in plain words. 
• Two-Key: identify co-signers and independence (IPP screen + timestamps) where 
consequential. 
• Number everything: evidence IDs, pages, annexes; log a provenance hash. 
• Service timelines: serve the person/representatives ≥5 business days before hearing 
(unless urgent); attach a plain-language version. 
• Small-cell suppression for any public release (Appendix S/AL). 
 
Scope 
All Tribunal/OPA matters: restrictive-practice authorisations/variations; 
guardianship/administration; health/medication orders; reviews; responses to OPA notices. 
Ombudsman or DSC request packs use the same templates (with their cover page per AG.1). 
Navigators may prepare family-facing summaries; the same evidence set is used across 
bodies. 
 
The Candour Pack  -  structure & exemplars 
1) Plain-English Notice to the Person (exemplar AG-1A) 

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• What is happening and when. 
• Why (plain purpose; any immediate risks). 
• Your rights: support person, interpreter/Auslan, AAC, see the papers, tell your side. 
• What we are asking for (short bullets). 
• How to contact us (named person). 
• Accessible versions (Easy Read, audio, translated, Auslan). 
2) Decision Dossier (exemplar AG-2A) 
A) Issues (numbered) 
B) Evidence table with weights (R&W) 
ID Source Date Summary Weight (0-
4) 
Why this weight 
(≤25w) 
E01 Video 02:14-03:03 12 
Aug 
pacing/exit toward 
road 4 direct, time-stamped 
E02 Staff note 
(unsigned) 
13 
Aug “often aggressive” 1 hearsay; no detail 
E03 Pharmacy review 15 
Aug PRN 3×/wk 3 independent; clear 
count 
C) Contradiction Matrix (hearing version)  -  conflict, principle(s) (see Appx I), preferred 
item, confidence, follow-up/owner/date. 
D) Applied tests  -  necessity; least-restrictive; lawfulness; proportionality; 
candour/integrity; privacy/suppression (≤25 words each, cite IDs). 
E) Orders sought & safeguards  -  time-limited; review dates; fade steps; practice actions 
“tomorrow morning”. 
3) Safeguards Annex (exemplar AG-3A) 
• Access provided (interpreters/Auslan/AAC; consent mode/attestation). 
• DPIA summary (minimum data; suppression plan if publishing). 
• Authorisations & expiries (if RP/psychotropic). 
• Reviews booked (72-hour, next panel/tribunal date). 
• First Nations protocols (MOU, wording review). 
• Two-Key co-signers, independence screen (IPP), timestamps. 
4) Service & Provenance (exemplar AG-4A) 
• Who received what, when, and how (person, representative, OPA, counsel). 
• Hashes & audit events (bundle + attachments; Appendix T IDs). 
• Contact sheet (hearing day). 
• Cross-references if also lodged with Ombudsman/DSC (AG.1). 
 
Will & Preferences Note (insert) 
• Method used (SDM/BIWP/AAC/interpreter) and who supported it. 
• The person’s own words (or best evidence of will/preferences). 

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• Dignity of risk considered; agreed supports; fade/expiry if restrictions are sought. 
 
Tier-0 Log & 72-Hour Review (for emergency pathways) 
• Trigger; immediate action; restraint/sedation minutes; outcome. 
• 72-hour review: attendees; alternatives; least-restrictive re-test; fade/next steps; 
learning points; next review date. 
• Outputs: updated R&W short form; Matrix updates; reasons digest; audit hash; 
publication note. 
 
 
 
DSC Calibration Memo (Two-Key)  -  for contested/complex matters 
• File vs field checks: second-key independence; rotation; R&W quality; will & 
preferences fidelity; small-cell guard. 
• Variances; corrective actions; publication note (non-PII). 
• Feeds Owner Matrix (Y) and tiles (S-Q02, S-P06). 
 
Candour by Template  -  exemplars 
 
Exemplar AG-1A  -  Plain-English Notice (≤200 words) 
You have a hearing on [date/time] about [topic]. We are asking the Tribunal to consider 
[short ask]. This is because [plain reason]. You have rights: you can bring a support person; 
we will provide an interpreter/Auslan or AAC if you want one; you can read these papers; 
you can tell the Tribunal what you want. What matters to you: [two lines captured in intake]. 
If the Tribunal makes any short-term order, it will be checked again in 72 hours. Call [name, 
number] if you need help. Easy Read/Auslan video versions are available. 
Exemplar AG-2A  -  Orders & Safeguards block (≤120 words) 
We seek a time-limited order to [scope] for [days/weeks]. Safeguards: start/stop timing; 
second-key co-sign; 72-hour review booked [date]; fade plan steps: [1-2 bullets]; 
consent/communication supports in place; publication is de-identified with small-cell 
suppression; next review [date]. 
 
Timing & service 
• Standard: serve ≥5 business days before hearing; interpreters booked; Easy Read 
provided. 
• Urgent: registrar contacted; serve what exists now + list what follows (with dates). 
• After hearing: share the order + one-page plain summary with the person/family 
same/next business day. 
 

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Ombudsman & DSC pathway (AG.1  -  same pack, routed) 
Who gets what (routing matrix) 
Body When to notify What to send 
Tribunal/OPA Applications, variations, 
reviews, urgent orders Full Candour Pack (AG-1A…AG-4A) 
   
Ombudsman Complaints/systemic issues; 
information requests 
Candour Pack + Ombudsman cover page (ref/due 
date) 
   
DSC Safety/quality notifications (S0-
S3) 
Candour core (facts timeline; R&W top items; 
Matrix if conflict; immediate controls; fix-forward; 
audit hashes) 
Timeframes (align to law): Tribunal/OPA ≥5 bd (unless urgent); Ombudsman by request 
due date; DSC S0 2h / S1 24h / S2 3bd / S3 7bd. 
One evidence set: same numbered R&W table and Matrix for all audiences; apply 
minimum data + suppression/redaction for any public step; all packs carry hashes and audit 
IDs. 
 
Hearing-day roles & quick scripts 
• Presenter: “We’ll show both the helpful and unhelpful facts. The person’s position is 
on page 2.” 
• If challenged: “That item is E02 (weight 1). We prefer E01 because it’s direct and 
time-stamped.” 
• To the person: “If you need a pause or interpreter change, tell us by 
[gesture/word].” 
 
Measures (internal; some publishable) 
• Bundles on time (%) · Interpreter/Auslan fulfilment (%) · Packs returned for defect 
(%) (↓) · Orders with least-restrictive safeguards (%) · Reviews booked inside 
standard (%) · Post-hearing actions on time (%). 
 
Micro-scenarios (worked) 
• Urgent medication order: Short pack filed same day; interpreter by video; time-
limited order; taper review in 14 days. 
• RP variation: PRN drift shown; alternatives added; order amended with strict 
start/stop timing and fade steps; 4-week review set. 
• Guardianship review: Person’s AAC statement leads; Matrix prefers recent video + 
pharmacist review over old note; limited-scope order with review date. 
 

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Where to get help / Artefacts & Templates 
• AG-1A Plain-English Notice (Easy Read + translated/Auslan) 
• AG-2A Decision Dossier shell (Issues → R&W → Matrix → Tests → Orders & 
Safeguards → Actions) 
• AG-3A Safeguards Annex 
• AG-4A Service & Provenance sheet (hash fields + multi-recipient log) 
• AG-5 Ombudsman cover page (ref, scope, due, contact) 
• AG-6 Pack routing checklist (AG.1)  -  Tribunal / OPA / Ombudsman / DSC 
• AG-7 Post-hearing plain summary (≤1 page; distribution list) 
 
Summary companion. One pack, many audiences. Numbered, weighted evidence; 
contradictions resolved; Two-Key and 72-hour learning loop visible; small-cell 
suppression and audit hash in place; safeguards that fade by default. Candour by template 
turns hearings from guesswork into accountable decisions. 
 
Appendix AH  -  Fiduciary Safeguards & Financial Safety Pack 
Protect the person’s money; make spending transparent; stop harm early. 
Owner: Finance & Governance (with Practice Lead) 
Interfaces: E-Receipts (Appx E); Roster↔Claim Cross-Checks (Appx F); Sanctions Ladder 
(Appx G); Audit Log (Appx T); DPIA & Publication (Appx R/S); Switching Protocol (Appx 
M); Owner Matrix & Escalation (Appx Y); Communication Access (Appx N); Tribunal/OPA 
& Ombudsman (Appx AG). 
Why this matters (and why it hasn’t worked) 
People have lost money through cash handling, vague approvals, gift cards, and “we’ll fix 
it later” reimbursements. Records are scattered, families can’t see what was spent, and small 
leaks become large losses. A clear Financial Safety Pack puts the person first: simple 
permissions, cash-free where possible, two-party evidence, fast reimbursements, and red-
flag alerts. 
Fast take (read this first) 
• Cash-light by design: prefer pre-paid card or account with limits; no loose petty 
cash. 
• Two-party proof: every purchase has an e-receipt + staff attestation (Appx E). 
• Plain “Money Agreement” with the person/family sets what’s OK, who can help, 
and how to see statements. 
• Red-flags watched daily; escalate by S-level (below). 
• Quarterly plain summary for the person/family; privacy-safe public tiles only. 
• Everything auditable (Appx T) and switch-ready (Appx M). 
Scope 

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All spending on behalf of the person: food, travel, outings, subscriptions, equipment, 
phones/tablets, and small home items - whether funded by plan budgets or the person’s own 
money. Applies to in-home, community, day program, short-stay and rural micro-hub. 
 
Roles (R/A/C/I) 
• A: Finance & Governance Lead 
• R: Team leaders / key workers (day-to-day approvals) 
• C: Person/representative; family/guardian; Cultural broker/ACCO (where relevant) 
• I: Practice lead; Ombudsman/OPA when escalated; Vendors/banks for fraud blocks 
 
Person-first rules (plain) 
1. It’s their money. Get consent in their way (Appx N). Keep purchases aligned to their 
goals. 
2. No cash unless written in the Money Agreement; if used, count/receipt/lock 
immediately. 
3. Cards & PINs: personal to the person; if staff must assist, use sealed PIN, named 
custody log, and two-party use. 
4. Conflict of interest: staff don’t buy from or sell to people they support. No “points 
farming”. 
5. Fast fixes: if anything feels off, stop and tell a supervisor - same shift. 
 
Financial Safety Pack  -  contents (what every site must keep current) 
1. Money Agreement (plain English/Easy Read)  -  what’s OK to buy, weekly caps, 
card rules, who can see statements, consent mode. 
2. Spending Permissions Map  -  who can approve what (limits by role & item). 
3. Pre-paid/Card Register  -  card IDs, holders, limits, PIN custody, lost/stolen steps. 
4. E-Receipt Workflow  -  how staff capture itemised receipts and attest two-party 
(Appx E). 
5. Reimbursement & Cash-out SOP  -  allowed cases only; timeframes; evidence. 
6. Red-Flag Triggers & Escalation Tree  -  see S-levels below. 
7. Quarterly Person/Families Summary  -  simple pie chart + top vendors (private). 
8. Switching/Exit Checklist  -  close cards, export statements, hand back balances 
(Appx M). 
 
Everyday workflow (1-page) 
Before buying 
• Check the Money Agreement and the limit. 
• If not listed or over limit → get approval (phone/SMS log is fine if captured in the audit log). 
At purchase 

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• Use the person’s card (preferred) or approved method. 
• Capture itemised e-receipt (photo/upload) and two-party attestation. 
After purchase (same day) 
• Tag to the person and category; add short note (“bus pass”, “entry fee”). 
• If mistake or damaged item → start refund/return the same day. 
Weekly 
• Team lead reviews exceptions (missing receipts, split transactions). 
• Courtesy check: anything unusual? If yes, call family/representative. 
 
Red-flags & escalation (financial harm ladder) 
Level Examples (not exhaustive) First response Notify/escalate 
S0 
Critical 
Cash withdrawal at ATM; card used when 
person not present and not in plan; 
repeated high-value electronics; 
forged/edited receipt; suspected theft 
Immediate stop card; 
make safe; inform 
person; start facts log 
On-call + A in 15 min; 
Ombudsman/OPA if harm/abuse 
suspected; police per policy; 
audit log 
S1 High 
Three missing receipts in a week; split 
transactions to dodge limit; vendor linked 
to staff; denial of access to statements 
Freeze spending to 
essentials; collect 
facts; courtesy-call 
family 
A within 2 h; improvement plan 
in 24 h; consider sanctions (Appx 
G) 
S2 
Medium 
Late reimbursements; plan purchase not in 
goals; repeated subscriptions 
Fix within 3 days; 
coach staff; update 
Money Agreement 
Team lead; monthly review 
S3 Low Single small error; price above usual 
without reason 
Correct same day; 
note reason Team lead; watch list 
Auto-promote if unsure. Downgrade only by A after facts recorded. 
 
Controls (what must exist) 
Cards & accounts 
• Pre-paid or debit with per-transaction and daily caps; merchant blocks (e.g., 
gaming, liquor) where appropriate. 
• No shared cards. One card per person; custody log when staff carry it temporarily. 
• Lost/stolen = immediate block + report. 
E-receipts & approvals 
• Itemised receipt + 2-party attestation fields: who bought, who witnessed, purpose, 
location, timestamp (Appx E). 
• Roster↔claim cross-check (Appx F): spending must line up with support actually 
delivered. 
Reimbursements 
• Only for pre-approved cases or true emergencies. 

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• Timeframe: submit same day; pay within 5 business days. 
• Evidence: itemised receipt; reason why card was not used; approval ID. 
Gifts/benefits register 
• Record any gifts from vendors/families; no kickbacks. 
Privacy 
• Statements shared with person/family per Money Agreement; minimum data in any 
public release (Appx S); all packs hashed (Appx T). 
 
Measures (internal; some publishable) 
• e_receipt_coverage_pct (target ≥98%) 
• exceptions_per_100_tx (downward trend) 
• missing_receipt_rate (≤1% with rapid correction) 
• time_to_reimburse_median_days 
• card_custody_breaches_count 
• split_tx_detected_count and vendor_conflict_hits 
• Courtesy-check completion (%) and satisfaction (short 3-emoji scale) 
• Publish only safe aggregates per Appx S. 
 
Micro-scenarios (worked) 
• ATM withdrawal detected (S0): Card blocked in 10 min; person safe; facts log 
shows staff error; training + limit changes; family updated same day; Ombudsman 
advice sought; card reinstated with custody log tightened. 
• Missing receipts x3 (S1): Freeze non-essentials; 24-hour improvement plan; staff 
coached on e-receipts; coverage returns to 99%; monitored for 30 days. 
• Subscription creep (S2): Music + video + game passes stacking. Team reviews 
goals; keep one, cancel two; Money Agreement updated; spend drops $35/month. 
 
Do / Never do (baseline) 
Do: keep it cash-light; use two-party e-receipts; match spend to goals; call early if something 
feels wrong; share simple quarterly summaries. 
Never do: hold a person’s card “just in case”; share PINs on paper; buy from staff/family 
businesses; accept “no receipt available”; delay reimbursements. 
 
Switching & exit (must-do) 
• Close/transfer cards; hand back balances; export 12 months of statements and e-
receipts with hashes; update contact emails/phone on any online stores; confirm 
device/account sign-outs (Appx M). 

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Quick scripts 
• To the person/family: “It’s your money. We use your card where possible, keep 
receipts, and send you a simple summary each term. If anything looks wrong, we fix it 
fast.” 
• To staff: “If you can’t get an itemised receipt, don’t buy it - or call first. Two-party 
proof every time.” 
• To a vendor: “We need itemised receipts - GST or not. Please include product 
names, not just ‘miscellaneous’.” 
 
Where to get help / Artefacts & Templates 
• AH-1 Money Agreement (Plain English + Easy Read) 
• AH-2 Spending Permissions Map (limits by role/item) 
• AH-3 Card & PIN Custody Register 
• AH-4 E-Receipt & Attestation Form (aligned to Appx E schema) 
• AH-5 Reimbursement & Cash-out SOP (with timeframes) 
• AH-6 Red-Flag & Escalation Tree (S0-S3) 
• AH-7 Quarterly Family Summary template (private) 
• AH-8 Vendor Letter (receipt requirements & contact) 
• AH-9 Switching/Exit Financial Checklist 
• AH-10 Gifts/Benefits Register 
 
Summary companion. Decisions rely on the governing sections named in E-Receipts, 
Cross-Checks, Audit Log, DPIA/Publication, Owner Matrix & Escalation, Sanctions 
Ladder, Communication Access and Tribunal/OPA/Ombudsman protocols. 
 
Appendix AI  -  Industrial Relations & Insurance Brief Templates 
Clear briefs mean faster fixes, safer work, and fewer disputes or claim surprises. 
Owner: People & Culture (HR) with Legal/Insurance Lead 
Interfaces: Owner Matrix & Escalation (Appx Y); Safety & Restrictive Practices (Appx A); 
72-Hour Review & Fade Plan (Appx B-C); Handover & Medication Reconciliation (Appx 
D); E-Receipts & Cross-Checks (Appx E-F); Sanctions Ladder (Appx G); Red-Team (Appx 
U); DPIA & Publication (Appx R/S); Audit Log (Appx T); Workforce/IDC & OSCEs (Appx 
Q); Switching Protocol (Appx M); Ombudsman/Tribunal (Appx AG). 
Why this matters (and why it hasn’t worked) 
Industrial issues and insurance notifications are often late, wordy, or missing facts. That 
raises legal risk, slows return-to-work, and can void cover. With short, standard briefs - 
written in plain English and backed by the same evidence tables we use elsewhere - unions, 
staff, and insurers see the same picture and can act quickly. 

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Fast take (read this first) 
• Use two streams of templates: 
1. IR/Workforce (consultation, change, investigation, dispute). 
2. Insurance (notify early; facts only; no admissions). 
• One evidence set everywhere: R&W table, Contradiction Matrix, audit hashes. 
• Link actions to the Owner Matrix and IDC/OSCE requirements (competence, 
supervision). 
• Time matters: notify insurers promptly; start consultation before change; keep the 
tone respectful and factual. 
Scope 
All workforce and insurance matters across home, community, day program, micro-hubs and 
health interfaces: roster changes, new IDC roles, OSCE currency requirements, disciplinary 
investigations, protected disclosures, industrial disputes; workers’ compensation, professional 
indemnity, public liability, motor, property, and cyber/privacy incidents. 
 
When to use which brief (quick matrix) 
Situation Use these templates Timeframe 
Roster redesign / new IDC model 
/ micro-hub 
AI-1 Consultation Brief, AI-2 Staff & Union 
Cover Note, AI-3 Role/Scope Statement 
Start before change; 
give clear dates 
   
Practice concern / misconduct / 
incident with worker harm 
AI-4 Investigation ToR & Witness Care, AI-5 
Suspension/Stand-Down Notice (if used) Same day as decision 
   
Worker injury / psychological 
harm 
AI-6 First Report (Workers’ Comp), AI-7 RTW 
Plan Stub 
24 h to insurer (earlier 
if policy says) 
   
Family/third-party claim risk 
(service error, injury) AI-8 Liability Notice (PI/PL) + R&W pack Immediately / next 
business day 
   
Vehicle damage / road incident AI-9 Motor Claim First Notice + photos/map 24 h 
   
Privacy/cyber incident AI-10 Cyber/Privacy Notice + DPIA snippet Immediately / 
regulator windows 
   
Data or publication complaint AI-11 Ombudsman Cover Page + Candour pack Per request due date 
   
Industrial dispute / grievance AI-12 Dispute Brief & Resolution Plan On receipt (same/next 
business day) 
Always attach: R&W top items, Contradiction Matrix (if accounts conflict), audit event IDs 
& hashes (Appx H/I/T). 
 
IR stream  -  core rules (plain) 

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1. Consult early, not after the fact. Give reasons, options, dates, and invite 
alternatives. 
2. Separation of roles: one person runs the process, another supports the worker. 
3. Safe participation: interpreters/Auslan/AAC offered; no retaliation for raising issues. 
4. IDC competence: any change must show OSCE/IDC coverage and supervision 
(Appx Q). 
5. Keep to facts: use short, numbered points; avoid labels and opinions. 
AI-1 Consultation Brief (change proposal)  -  structure 
• What is changing & why (1-2 paras; link to participation/safety goals). 
• Who is affected (roles/locations/FTE). 
• Options considered (keep/change/phase-in; pros/cons). 
• Impact summary (rostering, allowances, travel, training). 
• IDC/OSCE coverage (how competence is kept). 
• Support offered (training, redeployment, EAP). 
• How to respond (contact, dates, meeting times). 
• Attachments: draft roster map, role/scope statements, FAQs. 
AI-2 Staff & Union Cover Note (plain) 
• Plain words; invite discussion; list access supports; set consultation window and a 
decision date. 
AI-3 Role & Scope Statement (IDC-linked) 
• Purpose • Key tasks • Boundaries (what you must not do) • Supervision • OSCE 
requirement • Licences/clearances • Pay/allowances • Review date. 
AI-4 Investigation Terms of Reference (ToR) & Witness Care 
• Allegation(s) in plain English • Scope (what is and isn’t included) • Process 
(interviews, documents) • Standards referenced • Timeframe • Support offered • 
Privacy & non-retaliation notice. 
AI-5 Suspension/Stand-Down (if used) 
• Reason (link to risk or process fairness) • Pay status • Duration/review dates • 
What you can/can’t do • Contacts & supports. 
 
Insurance stream  -  core rules (plain) 
1. Notify early (often “as soon as practicable”): send facts only; no admissions of 
liability. 
2. One contact point to the insurer (Legal/Insurance lead). 
3. Bundle the facts: short timeline, R&W table, photos/maps, contracts/consents, policy 
numbers. 
4. Keep privilege clean (if legal advice is sought). 
5. Support the person/worker while the claim runs (separate from liability position). 

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Common policies & what they expect 
• Workers’ Compensation: first report, injury details, duties/RTW plan, medical 
certificates. 
• Professional Indemnity (PI): alleged error/omission; who, when, what harm; steps 
taken to mitigate. 
• Public & Products Liability (PL): incident details, maintenance logs, third-party 
contacts. 
• Motor: driver details, police number, photos, repairer info. 
• Property: asset list, photos, cause, invoices/quotes. 
• Cyber/Privacy: what data, how many affected, containment, regulator timelines, 
notification plan. 
AI-6 Workers’ Comp First Report  -  fields 
• Worker details • Incident date/time/place • What happened (≤6 bullets) • Immediate 
treatment • Duties at time • Witnesses • Access provided (interpreter/AAC) • Early 
contact to worker & RTW plan booked. 
AI-7 Return-to-Work (RTW) Plan Stub 
• Capacity (hours/tasks) • Adjustments • Supervisor check-ins • Treatment schedule • 
Review dates • Worker agreement (plain consent). 
AI-8 PI/PL Notice to Insurer (no admissions) 
• Policy # • Event summary (facts) • Parties involved • Harm reported • Controls in 
place • Documents list • Contact for further info. 
AI-9 Motor Claim First Notice 
• Driver/licence • Vehicle details • Photos/diagram • Police/incident # • Repairs/ tow • 
Injuries (if any). 
AI-10 Cyber/Privacy Notice 
• Data type/volume • Containment • Forensics started? • Legal/regulator timelines • 
Draft comms (plain) • DPIA snippet • Audit IDs. 
 
Evidence & tone (for both streams) 
• Use R&W table (max 6 items) with weights 0-4 and one-line reasons. 
• If accounts conflict, add the Contradiction Matrix (principles; preferred item; 
confidence; follow-up). 
• Attach only what is needed; de-identify where possible; add hashes & audit events. 
• Plain, respectful, and specific. No blame language. 
 
Measures (internal; some publishable) 

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• Consultations on time (%) (opened before change). 
• Workers’ comp first-notice timeliness (%) and median RTW days. 
• Insurer notifications on time (%) by policy. 
• Investigation cycle time (open → close, median). 
• Repeat disputes (same topic/site) down. 
• IDC/OSCE currency for affected roles (%) during/after change. 
 
Micro-scenarios (worked) 
• Roster redesign for micro-hub: AI-1 sent 3 weeks early with options; union chooses 
phased roll-in + travel allowance tweak; OSCE sessions scheduled; change lands 
without dispute. 
• Vehicle scrape in carpark: AI-9 filed same day with photos; no injury; repair 
approved; driver debriefed. 
• Family injury claim (slip): AI-8 sent with maintenance log and photos; hazard fixed; 
PI handles correspondence; plain apology issued without admitting liability. 
• Data email error: AI-10 submitted within hours; 16 families notified with plain 
message; regulator timeframes met; no Ombudsman escalation. 
• Worker strain injury: AI-6 + AI-7 lodged; duties adjusted; RTW in 9 days; IDC 
supervision increased for manual-handling refresh. 
• Practice allegation: AI-4 ToR set; interpreter provided; Matrix resolves note vs 
video; outcome letter cites standards and support offers. 
 
Quick scripts 
• To staff & union (consultation): “Here’s what we’re changing and why. These are 
the options and dates. Tell us better ideas - we’ll publish the decision and reasons.” 
• To an insurer (first notice): “Facts attached, evidence numbered and hashed. Please 
confirm coverage position and next steps. No admissions are made.” 
• To a worker (injury): “We’ll lodge the claim today and build a duties plan with you. 
Your health comes first.” 
• To a family (privacy/cyber): “A mistake happened with your data. Here’s what, 
what we’ve done to protect you, and how to get help.” 
 
Where to get help / Artefacts & Templates 
• AI-1 Consultation Brief (change proposal) 
• AI-2 Staff & Union Cover Note (plain) 
• AI-3 Role & Scope Statement (IDC-linked) 
• AI-4 Investigation ToR & Witness Care pack 
• AI-5 Suspension/Stand-Down letter (if used) 
• AI-6 Workers’ Comp First Report 
• AI-7 Return-to-Work Plan stub 
• AI-8 PI/PL Insurer Notice 
• AI-9 Motor First Notice 
• AI-10 Cyber/Privacy Notice 
• AI-11 Ombudsman Cover Page (with Candour pack link) 

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• AI-12 Dispute Brief & Resolution Plan 
• AI-13 Evidence bundle index (R&W + Matrix + hashes) 
 
Summary companion. Decisions rely on the governing sections named in Owner Matrix 
& Escalation, Safety & Restrictive Practices, Truth-by-Design (R&W/IRC), 
Workforce/IDC & OSCEs, DPIA/Publication, Audit Log, Sanctions Ladder and 
Tribunal/OPA/Ombudsman protocols. 
 
Appendix AJ  -  Research & Evaluation Partnership MoU 
Work together, protect people, share results that improve everyday life. 
Owner: Evaluation & Governance (with Practice Lead) 
Interfaces: Evaluation Access Protocol (Appx W); DPIA & Publication (Appx R/S); Audit 
Log (Appx T); First Nations Partnership (Appx O); Interpreter/Auslan/AAC (Appx N); 
Switching Protocol (Appx M); Owner Matrix & Escalation (Appx Y); Workforce/IDC & 
OSCEs (Appx Q); Tribunal/OPA & Ombudsman (Appx AG). 
Why this matters (and why it hasn’t worked) 
Good studies have fallen over because approvals were vague, data left the building, or 
participants never heard back. Sometimes projects helped the paper more than the people. A 
plain MoU locks in ethics, access tiers, privacy, co-design, and what the community gets 
back - so research answers real questions without harm. 
Fast take (read this first) 
• Use one MoU for each partner, with a short Project Schedule per study. 
• Access follows Appx W (Tiers A-E). Start low; justify going higher. 
• Consent is real: accessible, recorded, revocable; interpreters/Auslan/AAC offered. 
• Independence & candour: pre-register methods; declare conflicts; publish a Plain-
English summary back to participants. 
• Data room, not email: de-identified datasets only; outputs checked for suppression. 
• Community benefit: training, feedback loops, and a change plan tied to IDC 
workforce. 
Scope 
Universities, research institutes, evaluators, and community partners working with any 
service, site or dataset covered by this White Paper. 
 
Partnership MoU  -  fillable template 
1) Parties & purpose 
• Parties (legal names) and leads (names/contacts). 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 298 
 
• Purpose: what questions we will answer and how this helps people now. 
2) Principles 
• Do no harm • Person first • Co-design with lived experience • First Nations protocols 
(Appx O) • Minimum data • Results back to the community. 
3) Ethics & approvals 
• Human Research Ethics Committee (HREC) approval or exemption numbers. 
• If clinical procedures: additional approvals listed. 
• Amendment protocol for changes. 
4) Access & data (point to Appx W + R/S) 
• Access tier(s) requested (A-E) and justification. 
• Data room use for de-identified data; no raw exports. 
• Pseudonym keys kept separate; small-cell suppression and rounding for any publication. 
• Retention period; secure deletion; provenance hashes (Appx T). 
5) Consent & supports 
• Consent materials (Plain English + Easy Read; interpreter/Auslan/AAC options). 
• Mode recorded (tap/PIN/biometric/verbal-witnessed/alt-comm) and withdrawal path. 
• Payment/reimbursement for participant time; no coercion. 
6) Co-design & governance 
• Lived-experience advisors named; meeting schedule; decision rights. 
• IDC workforce link: which OSCE/skills sessions, shadowing or tool feedback the partner 
will provide back to the service. 
7) Roles & independence 
• Who does what (PI, data steward, privacy officer, cultural broker, analyst). 
• Conflicts of interest declared and managed. 
• Pre-registration (link) or method note if not feasible. 
8) Deliverables & timelines 
• Milestones (start; mid-point memo; draft; final). 
• Plain-English participant summary (≤2 pages) and practice note for services. 
• Training/briefing for staff or families (what, when). 
9) Publication & IP 
• Partner may publish findings, not raw data; provider has factual-accuracy check (not veto). 
• Authorship reflects contribution; lived-experience roles named. 
• Codebooks and analysis code shared back to provider (license: non-exclusive, non-
commercial unless agreed). 
10) Complaints, safety & escalation 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 299 
 
• Follow Owner Matrix (Appx Y) for any incident; pause if a stop-rule fires. 
• Ombudsman/Tribunal contact points (Appx AG) if a complaint overlaps. 
• Whistle-blower and grievance paths for participants and staff. 
11) Term, variation & exit 
• Start/end dates; renewal option. 
• Exit for breach or harm; data return/destroy with hash receipts. 
• Surviving clauses: privacy, IP, acknowledgement, community summary. 
12) Signatures 
• Provider lead; Partner lead; Cultural authority (if First Nations partnership); Date. 
 
Project Schedule (attach per study) 
• Title & brief aim • Access tier(s) • Sample & recruitment (equity notes) • Measures & 
tiles (Appx S codes) • Analysis plan • Risks & mitigations • Outputs (reports, code, 
training) • Dates • Contacts. 
 
Guardrails (what must never slip) 
• No family-as-interpreters for serious matters unless emergency, then replace ASAP. 
• No recording without consent & DPIA. 
• No raw person-level data offsite. 
• No “surprise” methods; changes go back to HREC and MoU signatories. 
• Community gets the Plain-English summary - always. 
 
Measures (internal; some publishable) 
• MoUs signed with co-design & ethics complete (%) 
• Projects delivering a Plain-English summary on time (%) 
• Time from request → data room access (median days) 
• Findings adopted into practice within 90 days (%) 
• Participant satisfaction (short 3-emoji scale) 
• Privacy incidents = zero; small-cell breaches = zero 
 
Micro-scenarios (worked) 
• School transition study: Tier D data room; 8-week analysis; summary shows “visual 
schedule + transport ally” doubles attendance. Practice note updated; results posted in 
plain English. 
• Rural micro-hub pilot: Tier C observation + Tier D data; co-design with local 
ACCO; partner delivers two IDC mini-trainings; report uses suppression; travel time 
drops 28%. 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 300 
 
• Medication review audit: Tier D only; findings lead to stewardship tweak (Appx 
AB); 90-day follow-up shows PRN rate down 40%. 
 
Quick scripts 
• To a researcher: “Start at the lowest access tier that answers your question. We use a 
data room and we return a two-page summary to participants.” 
• To a participant: “You can say yes or no. If you say yes, we’ll use the least data, 
keep it safe, and tell you what we learned.” 
• To staff: “One evidence set, many audiences. If the method changes, we pause and 
re-approve.” 
 
Where to get help / Artefacts & Templates 
• AJ-1 Partnership MoU (fillable) 
• AJ-2 Project Schedule (one-pager per study) 
• AJ-3 Consent packs (Plain English, Easy Read, interpreter/Auslan/AAC options) 
• AJ-4 Data Room User Agreement (no raw exports; suppression checks) 
• AJ-5 Co-design & Governance charter (roles, meetings, decision rights) 
• AJ-6 Publication & IP addendum (authorship, accuracy check, code return) 
• AJ-7 Plain-English Participant Summary template 
• AJ-8 Provenance checklist (hashes, audit IDs, retention & deletion receipts) 
 
Summary companion. Decisions rely on the governing sections named in Evaluation 
Access, DPIA/Publication, First Nations Partnership, Interpreter/Auslan/AAC, Audit 
Log, Owner Matrix, Workforce/IDC & OSCEs, and Tribunal/OPA/Ombudsman 
protocols. 
 
Appendix AK  -  Operational Prompt Pack 
Keep people safe in Supported Independent Living (SIL) and Individualised Living Options 
(ILO) homes without reducing autonomy. 
Owner: Operations (Practice Lead + Site Managers) 
Interfaces: Owner Matrix & Escalation (Appx Y); Safety & Restrictive Practices (Appx A); 
72-Hour Review & Fade Plan (Appx B-C); Handover & Med Reconciliation (Appx D); E-
Receipts & Cross-checks (Appx E-F); Sanctions Ladder (Appx G); Publication & 
Dashboards (Appx S); DPIA & Privacy (Appx R); Interpreter/Auslan/AAC (Appx N); First 
Nations Partnership (Appx O); Transport (Appx AE); Dental (Appx AC); Psychotropic 
Stewardship (Appx AB); Evaluation Access (Appx W); Candour pack (Appx AG); Financial 
Safety (Appx AH); AT & AAC (Appx AF); Switching Protocol (Appx M). 
Minimum standards (must-haves) 
 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 301 
 
• Annual independent audit per dwelling; corrective actions tracked to closure and shared 
with the person/nominee in Plain English/Easy Read. 
• Risk-based upgrades funded and sequenced against a published defects list (highest risk 
first). 
• Dashboards show pass rates, incident trends and time-to-fix, segmented by site and risk tier. 
• No seclusion, ever. Bedroom doors and environmental features must not be used to isolate a 
person. 
 
Audit checklist (summary) 
 
Fire & life safety  -  interconnected smoke alarms (bedrooms/living), visual/vibration alerts 
as required; monthly test log; fire blanket/extinguisher; clear egress; doors openable from 
inside without a key; ramps/rails as needed; sprinkler rules by risk tier; local hazard plan 
(bushfire/flood/cyclone/heat). 
 
Mealtime & aspiration safety (IDDSI)  -  current plan visible and understood; correct 
textures/cuts; posture supports; documented supervision level; pantry/choke-risk controls; 
denture fit check; oral care routine; suction plan if clinically indicated. 
 
Bedroom door & privacy  -  privacy locks openable in emergency; written door policy with 
the person; no wedges/chocks; alarms only where risk-assessed and least-restrictive. 
 
Electrical, gas, water & environment  -  test/tag schedule; RCDs; service gas appliances; 
CO alarm where required; scald risk controls; non-slip/lighting in bathrooms and stairs. 
 
Why this matters (and why it hasn’t worked) 
People freeze in busy moments. Teams know the policy but not the next sentence or first 
three checks. That leads to missed consent, poor handovers, and over-use of restraint. This 
pack gives ready-to-say prompts with tiny checklists so care is safe, lawful and kind under 
pressure. 
Fast take (read this first) 
• Each prompt has four parts: Say → Check → Do → Record. 
• Use the lowest-risk path first; escalate using Appx Y (S0-S3). 
• Access first (Interpreter/Auslan/AAC). No access = no consent. 
• Time-keep any emergency restraint and log it (Appx A). 
• Everything leaves a one-line record you can write now and tidy later. 
Scope 
For frontline workers, coordinators and on-call leads across home, community, day programs, 
short-stay and health interfaces. 
How the prompts are built (standard) 
Format 
• Context (when to use) 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 302 
 
• Say (one or two sentences, plain) 
• Check (3 quick checks) 
• Do (the action order) 
• Record (minimum fields) 
• Escalate (who/when) 
 
Core operational prompts (ready to paste/print) 
 
1) Offer communication access (every meeting)  -  OP-01 
Context: starting any conversation, review, or visit. 
Say: “How do you want to communicate today? We have interpreters/Auslan/AAC/yes-no 
cards.” 
Check: (1) Interpreter/Auslan needed? (2) Person has device/board? (3) Quiet space 
available? 
Do: set supports; confirm teach-back (“tell me in your way what we’re deciding”). 
Record: supports offered/used; consent mode. 
Escalate: if access not possible → reschedule or move to quiet space; notify lead if urgent 
care cannot proceed. 
2) De-escalate early  -  OP-02 
Context: signs of rising distress. 
Say: “I see this is hard. We can pause, change the space, or choose a simpler step.” 
Check: (1) Pain/thirst/toilet? (2) Noise/light triggers? (3) Known calming phrase available? 
Do: lower stimuli; offer choice A/B; use the person’s calming phrase; invite ally. 
Record: trigger, choices offered, what worked. 
Escalate: if imminent harm → follow Appx A emergency steps, time-keep. 
3) Emergency restraint (last resort)  -  OP-03 
Context: immediate risk of serious harm. 
Say: “I’m helping to keep you safe for a short time. We’ll stop as soon as it’s safe.” 
Check: (1) Imminent risk? (2) Least-restrictive option? (3) Safe staff present? 
Do: apply brief hold per training; start timer; remove hazards; switch to comfort plan ASAP. 
Record: start/stop time, cause, who present, injuries, debrief booked. 
Escalate: S0/S1 per Appx Y; 72-hour review (Appx B). 
4) Mealtime/IDDSI ready  -  OP-04 
Context: any meal or drink. 
Say: “We’ll follow your mealtime plan. If anything feels unsafe we stop and try another 
way.” 
Check: (1) Right texture/drink? (2) Upright/positioning? (3) Supervision level? 
Do: set up; small test sip/bite; no talking while chewing; pause if cough/wet voice. 
Record: plan used, any changes, issues. 
Escalate: choking/aspiration risk → S0; mealtime review within 72 h. 
5) Transport start  -  OP-05 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 303 
 
Context: pickup. 
Say: “Next is the car to [place]. Do you want music off or window a little?” 
Check: (1) Wheelchair 4-point + lap/shoulder belt? (2) Calming kit (phones/headphones)? 
(3) Backup stop if traffic? 
Do: secure; drive smooth; choices; pull over early if distress. 
Record: securement check, route changes, any pause. 
Escalate: safety risk or near-miss → Appx Y; quick note to next worker. 
6) Medication PRN gate  -  OP-06 
Context: PRN being considered. 
Say: “Before medicine, let’s try your first steps: [two non-drug steps].” 
Check: (1) Indication present? (2) Non-drug steps tried/ruled out? (3) Max dose/interval OK? 
Do: follow Psychotropic Stewardship (Appx AB); monitor at 30-120 min. 
Record: indication, steps tried, time/effect, side-effects. 
Escalate: ≥2 PRNs/24h or ≥3/week → prescriber/pharmacist review. 
7) 72-hour review booking  -  OP-07 
Context: after incident/rescue/PRN as RP. 
Say: “We’ll meet within 72 hours to learn and adjust the plan. Who should be there?” 
Check: (1) Person/family availability + interpreter/Auslan/AAC? (2) Evidence gathered? (3) 
Roles set? 
Do: send invite; prep R&W table; bring Contradiction Matrix if accounts clash. 
Record: date/time, attendees, evidence list. 
Escalate: if no slot found in 24 h → manager. 
8) First Nations partnership check  -  OP-08 
Context: planning or publishing involving a First Nations person/community. 
Say: “We’ll follow cultural protocols. Who should we speak with to do this the right way?” 
Check: (1) ACCO/cultural broker engaged? (2) Consent language correct? (3) Publication 
wording reviewed? 
Do: align to Appx O; adjust plan; book broker. 
Record: contacts, decisions. 
Escalate: if disagreement on protocol → senior broker + manager. 
9) Dental desensitisation step  -  OP-09 
Context: clinic visit or rehearsal. 
Say: “We’ll try just one step today. If you show this card, we stop.” 
Check: (1) Ladder level? (2) Sensory kit (glasses/headphones)? (3) Stop-signal agreed? 
Do: run step; finish on a win; schedule next. 
Record: level attempted/achieved; seconds; barriers. 
Escalate: distress → 72-hour review insert (Appx AC). 
10) Money at point-of-sale  -  OP-10 
Context: buying on behalf of the person. 
Say: “We’ll use your card and keep the receipt. Is this what you want to buy today?” 

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Check: (1) In Money Agreement? (2) Within limit? (3) Receipt capture working? 
Do: purchase; e-receipt + two-party attestation. 
Record: what/why/where; exceptions. 
Escalate: red-flags → Financial harm ladder (Appx AH). 
11) Research consent  -  OP-11 
Context: study invite. 
Say: “This is optional. Saying no won’t change your supports. Would you like it in Easy 
Read or with an interpreter?” 
Check: (1) Access provided? (2) Risks/benefits explained plainly? (3) Withdrawal path 
offered? 
Do: record consent mode; give contact; schedule. 
Record: mode, date/time, supports. 
Escalate: any pressure/coercion concern → stop and notify governance. 
12) Complaints intake  -  OP-12 
Context: person/family raises a concern. 
Say: “Thank you for telling us. We’ll write this down in your words and tell you what will 
happen next.” 
Check: (1) Access? (2) Safety now? (3) Preferred contact/time? 
Do: capture facts; give reference #; set update time. 
Record: plain summary; access given; risk level. 
Escalate: S-level via Appx Y; link to Candour pack if tribunal/ombudsman likely. 
13) Publication preview  -  OP-13 
Context: numbers or stories going public. 
Say: “Let’s check privacy and wording. Could this identify anyone?” 
Check: (1) Small-cell suppression? (2) Cultural review if First Nations? (3) Consent for any 
story/photo? 
Do: apply Appx S rules; fix wording; log hash. 
Record: checks passed, who signed off. 
Escalate: doubts → governance holds release. 
14) Switching handover  -  OP-14 
Context: provider change. 
Say: “We’re moving your supports. Here’s what you’ll keep and who to call.” 
Check: (1) AT/AAC licences + vocab exports? (2) Money/receipts/statements handed over? 
(3) Schedule and contacts live? 
Do: deliver exit pack; confirm new team import; courtesy call after first shift. 
Record: checklist complete; any gaps. 
Escalate: gaps within 24 h → managers both sides. 
 
Keeping the pack live 
• Prompts live in the staff app and as two-sided pocket cards. 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 305 
 
• Add QR codes to relevant appendices (A, N, R, S, etc.). 
• Review prompts quarterly or after any S0/S1 event. 
• Localise calming phrases, contacts, and clinic details; keep the structure the same. 
 
Measures (internal; some publishable) 
• Interpreter/AAC offer rate at contact points (%) 
• 72-hour review booked on time (%) 
• Mealtime/IDDSI adherence audits (%) 
• PRN avoided after non-drug steps (%) 
• Financial exceptions per 100 tx (down) 
• Complaints acknowledged inside 2 bd (%) 
• Publication preview passes (%) 
• Switching pack completeness (%) 
 
Micro-scenarios (worked) 
• Crowded foyer → OP-02: Lights down, seat offered, headphones on; visit continues 
without restraint; note filed. 
• PRN request → OP-06: Noise trigger managed; PRN not needed; effect noted; 
prescriber not called. 
• Data release → OP-13: Tile suppressed for small cells; wording updated after ACCO 
review; safe publish. 
• Switching day → OP-14: Vocab exported/imported; card/receipts passed; courtesy 
call confirms first shift smooth. 
 
Where to get help / Artefacts & Templates 
• AK-1 Prompt Cards (OP-01…OP-14)  -  printable, two-sided 
• AK-2 Wall Posters  -  “Say • Check • Do • Record” quick view 
• AK-3 QR Sheet  -  links to the governing appendices for each prompt 
• AK-4 Audit Sample Form  -  monthly check of prompt use/records 
• AK-5 Localisation Sheet  -  calming phrases, clinic names, contacts 
• AK-6 Pocket App Pack  -  mobile-ready versions with tap-to-record lines 
 
Summary companion. Decisions rely on the governing sections named in Communication 
Access, Safety & Restrictive Practices, 72-Hour Review, Mealtime/IDDSI, Psychotropic 
Stewardship, Transport, Financial Safety, DPIA/Publication, Owner Matrix & Escalation, AT 
& AAC, and Switching policies. 
 
 

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Appendix AL  -  Publication & Dashboard Schema (Public, Family, 
Provider) 
Owner: Data & Integrity 
Interfaces: E-Receipts (Appendix E); Roster↔Claim Cross-Checks (Appendix F); Sanctions 
Ladder (Appendix G); Safety & Restrictive Practices; Participation/CPI; Workforce/IDC; 
Privacy/DPIA; Two-Key Register (IPP); DSC Audits; Navigator/Foundational registries; 
Audit Log Spec; Appendix S (tiles). 
 
Why this matters (and why it hasn’t worked) 
Reports have been dense, late and hard to compare. Families can’t see the things that matter; 
the public sees spin; providers can’t benchmark fairly. A single, consistent schema fixes this: 
the same tiles, same definitions, same update rhythm - with clear owners and system 
mappings - plus privacy protection and plain-English labels. 
 
Fast take (read this first) 
• One schema, three views: Public, Family, Provider. 
• Six public tiles + eleven QA tiles (see Tile map below). 
• Rates use clear denominators and rolling windows; trends are 3-point (↑ ↔ ↓). 
• Small-cell suppression and provenance hashes are mandatory. 
• Each tile lists Owner role and Source systems so responsibility and reproducibility 
are obvious. 
 
Scope 
All providers under this White Paper. Publication cadence is monthly (unless noted). 
Family/Provider views show more detail; Public view is privacy-safe. 
 
Tile map  -  owner & system mapping (add to S-tiles) 
Tile ID Label (short) Owner role Source systems (IDs) Views 
(P/F/Prov) Cadence 
S-P01 Two-Key coverage 
(%) 
Registry 
Analytics 
TwoKeyRegister; R&W store 
(H); DSC memos P/F/Prov Quarterly 
S-P02 Restraint 
min/1,000h 
Clinical 
Analytics 
Safety logs; E-Receipts; 
Roster↔Claim P/F/Prov Quarterly 
S-P03 Reasons on time 
(%) 
Registry 
Analytics 
R&W (H); IRC (J); 
Tribunal/NDIA exports P/F/Prov Quarterly 
S-P04 Navigator coverage 
(%) 
NDIA/PITC 
Data Steward 
Navigator reg.; PITC; E-Receipt 
handover flag P/F/Prov Quarterly 
S-P05 Foundational 
access time (days) 
Foundational 
Supports 
Steward 
Foundational registry; Bookings; 
E-Receipts P/F/Prov Quarterly 
S-P06 Documentation 
integrity score 
Data & 
Integrity 
E-Receipt store; Audit Log (T); 
Matrix (I) P/F/Prov Quarterly 

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Tile ID Label (short) Owner role Source systems (IDs) Views 
(P/F/Prov) Cadence 
S-Q01 72-hour reviews on 
time (%) 
Clinical 
Governance Safety logs; DSC tracker F/Prov 
Quarterly 
(monthly 
internal) 
S-Q02 DSC file-field 
concordance (%) 
DSC Panel 
Secretariat DSC audits; Shadow notes F/Prov 
Quarterly 
(monthly 
internal) 
S-Q03 Licensed-scope 
coverage (%) 
Workforce 
Licensing 
OSCE/IDC registry (Q); Rosters; 
E-Receipts F/Prov Quarterly 
S-Q04 
OSCE/EPA pass 
rate 
(COORD/OPS) 
Workforce 
Licensing 
OSCE/EPA registry; Licensing 
DB F/Prov Quarterly 
S-Q05 
COORD 
independence rate 
(%) 
Registry 
Analytics COI declarations; DSC notes F/Prov Quarterly 
S-Q06 Navigator warm 
handover rate (%) 
NDIA/PITC 
Data Steward 
E-Receipt handover flag; 
Navigator reg. F/Prov Quarterly 
S-Q07 Time to second key 
(hrs, median) 
Registry 
Analytics 
TwoKeyRegister; IPP 
timestamps F/Prov Quarterly 
S-Q08 
OPS gateway 
elapsed days 
(median) 
Operations Intake; Bookings; E-Receipts F/Prov Quarterly 
S-Q09 
Mandatory 
registration uptake 
(%) 
Regulator 
Liaison 
Regulator feed; Provider 
attestations F/Prov Quarterly 
S-Q10 E-receipt coverage 
(%) 
Data & 
Integrity E-Receipt store (T-10) F/Prov Monthly 
S-Q11 Roster-claim 
anomaly rate (%) Integrity Unit Roster; Claims; Integrity 
reconciler F/Prov Monthly 
Safety (legacy bundle for 
CPI pages)* 
Clinical 
Analytics Incidents; E-Receipts P/F/Prov Monthly 
Participation/CPI Variety, role depth Service 
Outcomes E-Receipts (CPI flags) P/F/Prov Weekly/Monthly 
Workforce IDC IDC-led shifts, 
OSCE currency 
Workforce 
Licensing Rosters; OSCE registry F/Prov Monthly 
* Keep legacy headings where used in CPI pages; they point to S-tiles for values. 
 
Tile set (definitions, method, update rhythm) 
Each tile includes: label, definition, numerator/denominator, window, cadence, suppression, 
notes. (Definitions live in Appendix S; this appendix binds them to owners/systems and 
views.) 
1) Safety (public bundle) 
• Meaning: Time in restraint/seclusion-like practices is reducing; reviews happen on 
time. 
• Measures: 
o restraint_minutes_per_1000hrs (rolling 90d, monthly). 
o 72h_review_completion_rate (rolling 90d, monthly). 
• Denominators: total support hours; total events requiring review. 
• Suppression: hide if events <5 (show “Insufficient data”). 

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• Owner/Systems: Clinical Analytics; Incidents/E-Receipts/Roster↔Claim. 
2) Participation (CPI) 
• Meaning: People are present in community with growing variety and role depth. 
• Measures: out-of-home sessions per person (median, rolling 28d, weekly); variety 
index (rolling 90d); role depth share. 
• Denominators: active participants; sessions from E-Receipts with CPI flags. 
• Suppression: small cells by site/suburb; publish provider-level aggregates. 
• Owner/Systems: Service Outcomes; E-Receipts (CPI). 
3) Integrity 
• Meaning: Claims match what happened; exceptions are resolved quickly. 
• Measures: roster↔receipt match-rate (%), exceptions resolved inside SLA (%), both 
rolling 28d, weekly. 
• Denominators: total receipts; total exceptions. 
• Owner/Systems: Integrity Unit; Roster, Claims, E-Receipts. 
4) Workforce 
• Meaning: People are supported by observed-competent staff. 
• Measures: shifts led by credentialed IDC (%), safety OSCE currency (%), rolling 
90d, monthly. 
• Denominators: total shifts; staff in scope. 
• Owner/Systems: Workforce Licensing; Rosters; OSCE/IDC registry. 
5) Candour & Complaints 
• Meaning: Issues are surfaced and closed with reasons. 
• Measures: plain-English reasons issued (count/yes-no); complaints closed inside 
standard (%), monthly. 
• Denominators: contested decisions; complaints in period. 
• Owner/Systems: Complaints Office; R&W/IRC store; Case system. 
Optional tiles: First Nations partnership; Interpreter/AAC fulfilment; Medication 
reconciliation ≤72h. Owners: First Nations Partnerships; Interpreter Service; Medication 
Safety respectively. 
 
Suppression & privacy rules (apply to all tiles) 
• Small cells: do not show counts <5 or rates derived from <5 events; render 
“Insufficient data”. 
• Geography: public maps use coarse areas; no addresses. 
• Time: no daily person-level streams on public pages. 
• Narratives: redact personal identifiers; use roles (e.g., “family member”, “worker”). 
• Link-outs: public links go to policy glossaries; Family view links to the person’s 
receipts/history. 
• Differencing guard: ±1-2% noise for tiny denominators; lock annual totals. 

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Data dictionary (minimum fields for each published point) 
Field Type Meaning 
tile_id string e.g., two_key_coverage, e_receipt_coverage 
label string Plain-English name 
value / value_pct number Metric value 
num integer Numerator (suppressed if <5) 
den integer Denominator 
window string e.g., rolling_90d, quarterly 
period_end date ISO-8601 
trend string “up”, “flat”, “down” (3-point based on last 3 periods) 
notes string Plain-English method caveats 
owner_role string Tile owner (from table above) 
source_refs array Upstream datasets (IDs) 
provenance_hash string SHA-256 of source bundle 
suppressed boolean True when small-cell rule applied 
definition_version string SemVer for compute logic 
Example payload (Public view) 
{ 
  "tile_id": "two_key_coverage", 
  "label": "Two-Key coverage", 
  "value_pct": 78.6, 
  "num": 121, 
  "den": 154, 
  "window": "quarterly", 
  "period_end": "2025-09-30", 
  "trend": "up", 
  "notes": "Consequential decisions with independent second key and R&W 
attached.", 
  "owner_role": "Registry Analytics", 
  "source_refs": ["twokey:v1", "reasons:v1"], 
  "provenance_hash": "a1f9…", 
  "suppressed": false, 
  "definition_version": "1.4.0" 
} 
 
View rules (who sees what) 
Public 
• Sees tile values, trend arrows, short method, last update date, and plain-English status notes. 
• Sees current Sanctions stage (Appendix G). 
• No person-level history. 
Family 
• Everything in Public plus: person’s receipt history, corrections, friendly explanations, and 
export to PDF. 
• Warnings when an exception involves their receipts and the outcome. 

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Provider 
• Everything in Family plus: exception queues, drill-downs by site/team (suppressed where 
small cells), and benchmarking vs sector median. 
• Internal QA tiles (S-Q) visible with amber/red flags and links to Improvement Plans. 
 
Publishing cadence & governance 
• Monthly release on the 7th for prior month; weekly for match-rate/exception SLA tiles; 
quarterly for S-P tiles. 
• Pre-publication quality gate: data validation, small-cell scan, plain-English check. 
• Audit log each release (dataset versions, hash, approver). 
• Correction window: factual errors corrected within 72 hours; change noted on the page. 
• Change-log tile (S-8) carries definition changes and comparability notes. 
 
What good looks like / Red flags 
Good: stable definitions; on-time releases; owner + system listed for every tile; clear trend 
commentary; suppression consistent; families can find and understand their history. 
 
Red flags: changed denominators without notice; late releases; tiles not reproducible from 
sources; long jargon notes; unsuppressed tiny numbers; no owner named. 
 
Micro-scenarios 
• Small provider: Only three restraint events in 90 days → Public safety tile shows 
“Insufficient data”; Family view still shows personal history. 
• Exception spike: Match-rate dips; exception SLA falls. Public tile shows trend ↓ with a 
note; Provider page links to an Improvement Notice (Appendix G). 
• Data correction: Provider reports an over-count. Release 1.1 corrects the numerator, 
provenance hash updates, change-log shows the fix. 
 
Artefacts to insert 
• Tile specification table (S-1 .txt with fields/denominators/windows/rounding) 
• Plain-English glossary (labels, method) 
• Suppression decision tree 
• Release checklist (validation, suppression, audit log) 
• Public page wireframe (example tiles and notes) 
 
Summary companion. One schema, three views - and every tile has a named owner and 
system mapping. That is how publication becomes trustworthy for the public, useful for 
families, and actionable for providers. 
 
 

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Appendix AM  -  Public Narrative & Media Plan 
 
Metrics & signals 
 
Reach, engagement and message pull-through (share of stories that correctly cite 
CPI/safety/candour); talent metrics (clicks to careers, trainee applications, rural bursary 
uptake); sentiment & accuracy score (fact-check); diversity of voices (First Nations, CALD, 
Auslan/Deaf, women, LGBTQ+, ageing 55+, rural/remote); complaint 
volume/themes/median days to resolution. 
 
Governance 
 
Lived-Experience Council reviews story pipeline and language; sign-off matrix: legal/privacy 
→ clinical → comms; archive assets with consent forms, alt-text and captions; maintain a 
change log; align story timing with dashboard preview window (10 days) to correct data pre-
publication. 
Speak plainly. Lead with people and proof. Protect privacy. Fix fast. 
Owner: Communications & Governance (with Practice Lead and Lived-Experience 
Advisors) 
Interfaces: Publication & Dashboards (Appx S); DPIA & Privacy (Appx R); Owner Matrix 
& Escalation (Appx Y); Candour by Template (Tribunal/OPA/Ombudsman, Appx AG); First 
Nations Partnership (Appx O); Interpreter/Auslan/AAC (Appx N); Safety & Restrictive 
Practices (Appx A); 72-Hour Review & Fade Plan (Appx B-C); Audit Log (Appx T); 
Financial Safety (Appx AH); Research MoU (Appx AJ); Operational Prompts (Appx AK). 
Why this matters (and why it hasn’t worked) 
Messages have been late, technical, or defensive. Families hear policy, not people; media 
sees gaps; small cells risk re-identification; updates arrive after rumours. A clear narrative 
and one media plan make our story consistent: participation up, harm down, proof attached, 
privacy protected - and when things go wrong, we say so and show the fix. 
Fast take (read this first) 
• One message house for all channels; update quarterly. 
• Plain language + access every time (Easy Read, interpreters/Auslan/AAC). 
• Candour: we include what went wrong, what we changed, and by when (Appx AG). 
• Privacy guardrails: small-cell suppression and wording checks before publish (Appx 
S/R). 
• Crisis cadence: acknowledge fast, explain facts we know, commit to next update 
time, and follow through. 
• Single source of truth: dashboard tiles (Appx S) + audit provenance (Appx T). 
Scope 
All external comms: press statements, interviews, social, website, dashboards, letters to 
families/partners, and responses to Ombudsman/Tribunal interest. Applies to routine news 
and incidents. 

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Message house (keep on one page) 
Top line: 
People with cognitive disability lead ordinary lives - safe, connected, and heard. We measure 
what matters and act on it. 
Three pillars (with proof): 
1. Access first, then consent. (Interpreters/Auslan/AAC offered every contact; Appx N; 
interp_fulfilment_pct tile.) 
2. Least-restrictive by design. (Restraint minutes down; 72-hour reviews on time; 
Appx A-C; tiles rp_minutes_per_1000h, 72h_review_on_time_pct.) 
3. Truth you can check. (Dashboards with suppression; audit hashes; Appx S/T.) 
Human proof points (swapable): short stories approved by the person/family, with consent 
recorded. 
 
Roles & approvals 
• Spokespeople: 
o Primary: Executive Lead (system/strategy). 
o Clinical/Practice: Practice Lead or named expert. 
o Lived-experience advisors: opt-in, supported and pre-briefed. 
• Approval ladder (normal): Draft → Practice check → Privacy check → Owner 
sign-off → Executive sign-off (if policy-level) → Publish. 
• Approval ladder (crisis, S0/S1): Comms drafts holding line in 30-60 min → 
Governance/Practice/Privacy 10-min huddle → Owner sign-off → Publish → Update 
on schedule set in holding line. 
• One inbox/phone for media; log every inquiry (time, outlet, topic, deadline). 
 
Accessibility & First Nations 
• Plain English first; Easy Read when appropriate; interpreters/Auslan for briefings. 
• Image descriptions; captions on video; readable PDFs avoided (HTML preferred). 
• First Nations: co-design message, check wording with ACCO/cultural authority; do 
not publish community-level numbers without agreement; use 
welcome/acknowledgement where relevant (Appx O). 
 
Risk & privacy guardrails (always apply) 
• No small cells (<5) in any table, map, or story; round and blur per Appx S. 
• Consent for stories/photos: mode recorded; withdrawal respected. 
• No operational detail that increases risk (e.g., de-identified but easily triangulated 
routines). 
• Provenance hash added to releases; corrections get a new hash and visible change 
note (Appx T). 

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• Tribunal/Ombudsman matters: use Candour pack framing; do not pre-judge 
outcomes (Appx AG). 
 
Channels & cadence 
• Owned: website newsroom, dashboard pages, email to families/partners, SMS for 
urgent alerts, social channels. 
• Shared: community radio, local papers, ACCO newsletters, venue partners (Quiet 
Hours, Appx AD). 
• Cadence: quarterly “state of play” + monthly practice note updates + incident-
specific updates as promised. 
 
Media inquiry triage (flow) 
1. Log inquiry (deadline, outlet, ask). 
2. Classify: routine / sensitive / crisis (link to Appx Y S-level). 
3. Check: privacy risks? active legal/tribunal? cultural review needed? 
4. Choose response type: written statement / interview with conditions / background 
briefing. 
5. Prepare: pull tiles, R&W highlights if needed, approved quotes. 
6. Close: send; confirm receipt; schedule follow-up; store in log with hash. 
 
Crisis communications (S0/S1) 
Holding line (first hour): 
“We’re aware of an incident at [place] today. Everyone is safe/being cared for. We’ve started 
our safety review and offered support to those involved. We’ll share an update by [time].” 
Second update (facts & candour): 
• What happened (plain) 
• What we did to make things safe 
• What we’re checking next (timeline + who leads) 
• When we’ll report again 
• No identities, no blame language, no speculation 
Close-out note (after review): 
• Findings in plain language (what went wrong/right) 
• Actions taken (owner/dates) 
• Any regulator/Tribunal/Ombudsman interface 
• Where the public can read the safe numbers (dashboard link) 
 
Do / Never do (baseline) 

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Do: speak to the person/family first; use lived-experience advisors; show proof (tiles); 
publish correction notes; thank critics when they’re right. 
Never do: identify people; argue on social media; “no comment” without context; publish 
small cells; use family as interpreters for serious matters (unless emergency, then replace 
ASAP). 
 
Measurement (internal; some publishable) 
• Time to first statement (median, by S-level) 
• On-time follow-ups (%) against promised times 
• Accuracy/corrections (count; downward trend) 
• Interpreter/Auslan provided for briefings (%) 
• Pickup & sentiment (earned media tone; community survey) 
• Dashboard preview passes (%) (Appx S checks) 
• Misinformation correction time (median) 
 
Micro-scenarios (worked) 
• Restraint sentinel (S0): 45-min holding line; family briefed first; next-day update 
cites Appx A timing + Appx B review; dashboard tile flagged for next cycle; 
Ombudsman/Tribunal noted if applicable. 
• Privacy email error: Same-day statement with numbers in bands, not counts; DPIA 
actions; families contacted first. 
• Great news (participation): Story with consented quotes; photo alt-text; tile trend 
over 2 quarters; ACCO partner co-release. 
 
Quick scripts (for spokespeople) 
• Core values: “Access first, least-restrictive always, truth you can check.” 
• On numbers: “Our dashboard uses privacy-safe tiles - no small cells, no guess-who.” 
• On criticism: “You’re right to ask. Here’s what we changed this week and when 
we’ll report back.” 
• On Tribunal/Ombudsman: “We’re using a candour pack - both helpful and 
unhelpful facts are included. Outcomes sit with the decision-maker.” 
 
Where to get help / Artefacts & Templates 
• AM-1 Message House (one-pager) 
• AM-2 Press Statement Template (routine; crisis holding; second update; close-out) 
• AM-3 Q&A Bank (restraint, privacy, participation, IDC workforce, finance safety) 
• AM-4 Social Copy & Alt-Text Guide 
• AM-5 Accessibility Checklist (language, captions, formats, interpreters/Auslan) 
• AM-6 First Nations Wording & Co-release Checklist 
• AM-7 Media Inquiry Log (deadline, ask, response, hash) 
• AM-8 Approval Matrix & Crisis Cadence Card 
• AM-9 Dashboard/Publication Suppression Check (Appx S) 

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• AM-10 Lived-Experience Brief & Support Plan 
• AM-11 Correction & Retraction Protocol (with visible change notes) 
 
Summary companion. Decisions rely on the governing sections named in Publication & 
Dashboards, DPIA/Privacy, Owner Matrix & Escalation, Candour 
(Tribunal/OPA/Ombudsman), First Nations Partnership, Interpreter/Auslan/AAC, 
Safety & Restrictive Practices, 72-Hour Review, Audit Log and Financial Safety 
policies. 
 
 
Appendix AN  -  Police Academy Integration Plan (Cognitive Disability 
Capability) 
Equip first responders to recognise, slow down, and resolve safely - every time. 
Why this matters (read first): Police often have seconds to decide in noisy, uncertain 
places. Current academy content skews to “mental illness/crisis” and generic de-escalation; 
cognitive disability (ID/ABI/Autism) is usually an elective, brief, or assumed knowledge. 
Without practical access skills and clear “first minute” drills, officers can misread behaviour, 
escalate force, or miss health risks. This plan gives police simple, repeatable methods that 
save lives and build trust. 
Owner: Police Academy (Curriculum & Operational Skills) with Justice/Community Safety 
Interfaces: Communication Access (Appx N); Safety & Restrictive Practices (Appx A); 72-
Hour Review & Fade Plan (Appx B-C); Handover & Med Reconciliation (Appx D - ED 
interface); First Nations Partnership (Appx O); Rural Micro-Hubs & Tele-OSCE (Appx P); 
Red-Team Scenarios (Appx U); Publication & Suppression (Appx S); DPIA/Privacy (Appx 
R); Candour (Tribunal/OPA/Ombudsman, Appx AG); Owner Matrix & Escalation (Appx Y); 
Transport (Appx AE). 
Fast take (read this first) 
• See it early, make time: recognise cognitive-disability clues; create a tactical pause 
(space, quiet, fewer voices). 
• Access first = safer calls: always offer plain words, yes/no/AAC, 
interpreter/Auslan (Appx N). No access = no informed directions. 
• Least-restrictive, time-kept: avoid prone; if emergency restraint is unavoidable, 
time-keep and hand over to health fast (Appx A). 
• One minute drill on arrival (below) + OSCE-backed training with lived experience 
(Appx Q). 
• One evidence set: after any serious event, run a 72-hour learning review with R&W 
table (Appx B-C, H). 
• Measure and publish safely: force/injury down; interpreter use up; repeat-call 
reduction (Appx S). 
Scope 

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Recruit training, in-service refreshers, call-taking/dispatch, patrol practice, custody & 
interview, transport, rural/remote, and ED/hospital interface. 
 
The “first minute” drill (carry card) 
Say: “I’m here to keep everyone safe. We’ll go one step at a time.” 
Check (10-15s): 
1. Noise/light - reduce if you can; one voice only. 
2. Access - offer yes/no/AAC; ask for a support person by name. 
3. Medical - breathing, bleeding, seizure signs; stop food/drink if choking risk. 
Do: slow your body; give a single clear direction; show (don’t crowd); allow extra 
time to process; use their calming phrase if known. 
Record later: what access you offered/used; any force used with start/stop time. 
 
Academy curriculum map (recruits + refreshers) 
Module Hours What officers learn (plain) Assessment 
1. Foundations: ID, 
ABI, Autism 3 
How cognitive disability differs from mental 
illness/intox; common communication/sensory profiles; 
rights & “reasonable adjustment” 
Short applied quiz 
2. Communication 
Access 4 Use of yes/no, pictures, devices; when/how to book 
interpreters/Auslan; “teach-back” 
OSCE station 
(direction 
comprehension) 
3. Behaviour = 
communication 3 Triggers (noise, queuing, pain); how to create time and 
reduce stimuli; ally/family use 
Scenario with lived-
experience coach 
4. Safety & least-
restrictive 4 Restraint hierarchy, time-keeping, avoid prone; 
medical red flags; custody transport rules OSCE + skills tick 
5. Scene types 6 Traffic stop; shop incident; missing person; DV call; ED 
hallway; short-stay house 3 OSCEs, rotating 
6. Custody & 
interview access 3 Accessible caution/rights; support person; AAC in 
interviews; breaks; recording 
Case write-up + 
roleplay 
7. First Nations 
interface 2 Protocols with ACCOs; language/cultural brokers; 
wording & consent Scenario + checklist 
8. Rural & Tele-
OSCE 2 Micro-hub kits; phone/video coach; long-drive de-
escalation Tele-OSCE check 
9. Data, DPIA & 
candour 2 Body-worn video boundaries; privacy; R&W tables; 72-
hour review Mini R&W exercise 
Refreshers: 4-6 hours yearly; red-team scenarios (Appx U) rotated by local pattern. 
 
Call-taking & dispatch (CAD updates) 
• Scripts to spot access needs: “Is the person speaking or using a device or cards?” “Is noise 
or light upsetting them?” 

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• Flags (non-diagnostic): COMM_ACCESS_NEEDED, PREFER_YES_NO, 
SUPPORT_PERSON:<name/phone>, SEIZURE_RISK, 
WANDERING_PATTERN:<place>. 
• Dispatch notes: approach quietly; one voice; avoid crowding; ask for ally; consider no siren 
on approach if safe; request interpreter/Auslan via comms if indicated. 
• DPIA: CAD fields minimised; purge rules; audit (Appx R/T). 
 
Patrol protocols (scene-type quick guides) 
Traffic stop (no response to commands): 
• Park safely; lights dim; single officer at window, open hands; one direction; show 
the action; allow time; use visual card. 
• If stimming/rocking: not automatically non-compliant or intoxicated - slow down. 
Shop incident (distress/possible “theft”): 
• Move out of line/aisle; reduce eyes on; ask ally to bring the item to counter; offer 
choice (pay/put back/leave). 
• Treat “bolt for the door” as escape from overload, not aggression. 
DV call with ID/ABI present: 
• Separate calmly; use plain yes/no; check injury/medical; avoid rapid questioning; 
call a support person. 
• Capacity/consent: use accessible rights script; involve OPA/guardian where relevant 
(Appx AG). 
Missing person/wandering: 
• Use known safe places pattern; request family/ally contact; avoid loud hailers; 
prepare quiet greeting on locate; offer water/shelter first. 
ED/hospital hallway: 
• Ask for mealtime/IDDSI or seizure plan; request quiet space; coordinate with 
security/clinicians; avoid crowding; no “chemical restraint” decisions by police. 
Custody, interview & transport 
• Rights & caution explained with Easy Read + teach-back; interpreters/Auslan/AAC 
offered; support person recorded. 
• Transport: 4-point chair tie-down + lap/shoulder belt only; no improvised 
harnesses (Appx AE). 
• Interview: short, concrete questions; no rapid yes/no stack; breaks; allow 
device/board; record consent mode. 
• If force used: avoid prone; time-keep; medical check; report with R&W summary 
and Contradiction Matrix if accounts clash. 
Post-incident learning (same playbook as services) 

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• 72-hour review with practice lead & lived-experience coach: what helped/hurt; what 
to change next patrol. 
• One evidence set: numbered items + weights; privacy applied; Ombudsman/Tribunal 
interface if relevant (Appx AG). 
• Red-team scenario created from the event for next month’s training (Appx U). 
 
Measures (internal; some publishable with suppression) 
• Use-of-force with known/disclosed cognitive disability (rate ↓). 
• Injuries to person/officer (rate ↓). 
• Interpreter/AAC offered & fulfilled (%) at relevant events (↑). 
• First-minute drill documented (%) on relevant CAD jobs (↑). 
• Repeat calls to same address for distress (↓). 
• 72-hour reviews on time (%) and OSCE pass rates (%). 
• First Nations co-response used (%) where indicated. 
(Public reporting uses Appx S suppression/rounding.) 
Do / Never do (baseline) 
Do: create time; one voice; offer access; use allies; step back if crowding; log start/stop times 
if force used; book a 72-hour review. 
Never do: shout multiple commands; assume intoxication; use family as interpreters for 
serious matters (except emergency, then replace ASAP); improvise restraints; publish small-
cell stories. 
Micro-scenarios (worked) 
• Freeway breakdown: Officer uses first-minute drill, turns off siren, gives one code 
gesture; person follows to shoulder; no force used; family arrives; note filed. 
• Night-time DV call: Easy-Read rights; Auslan interpreter on video; support person 
contacted; safety plan agreed; no arrest; next-day welfare check shows no recurrence. 
• Rural wandering: Tele-OSCE coach supports two officers; locate at usual footy 
oval; calm re-contact; water offered; safe return; red-team scenario built for region. 
Quick scripts (pocket) 
• Greeting: “I’m [name]. I’ll go one step at a time. Thumbs up for yes, flat hand for no?” 
• To ally: “What helps most right now - quiet, light down, or your calming phrase?” 
• If stopping activity: “Pause. We’ll breathe and try an easier step.” 
• If force unavoidable: “Short hold to keep safe - timer on - then we stop.” 
Where to get help / Artefacts & Templates 
• AN-1 First-Minute Drill Card (laminated, two-sided) 
• AN-2 CAD Scripts & Fields (COMM_ACCESS_NEEDED, PREFER_YES_NO, 
etc.) 
• AN-3 Recruit Curriculum & OSCE Rubrics (traffic/shop/DV/ED) 
• AN-4 Accessible Caution/Rights Script (Plain + Easy Read + Auslan link) 
• AN-5 Custody & Interview Access Checklist 

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• AN-6 Patrol Scene Guides (traffic, shop, DV, missing, ED) 
• AN-7 72-Hour Review Pack (R&W + Matrix) 
• AN-8 Red-Team Scenario Builder (turn an event into training) 
• AN-9 First Nations Co-response MOU stub (with ACCO) 
• AN-10 Tele-OSCE Kit (rural coach workflow & checklist) 
Summary companion. Decisions rely on the governing sections named in 
Communication Access, Safety & Restrictive Practices, 72-Hour Review, First Nations 
Partnership, Rural Micro-Hubs/Tele-OSCE, Red-Team Scenarios, Publication/Privacy, 
Candour (Tribunal/OPA/Ombudsman), Owner Matrix & Escalation, and Transport 
policies. 
 
Appendix AO  -  IDC Equivalency & Bridging Matrix 
 
Recognise real proficiency fast, bridge the gaps, and prove safety in practice. This includes 
community/frontline, education, clinical, justice/police, government/NDIS/regulation, 
and corporate/enablers  -  because titles don’t protect anyone from knowing what they must 
know. 
 
Owner: IDC Program (Workforce & Education) 
Interfaces: IDC Curriculum, EPA Logbook & OSCE Rubrics (Appx Q); Owner Matrix & 
Escalation (Appx Y); Communication Access (Appx N); Safety & Restrictive Practices + 72-
Hour Review (Appx A-C); Handover & Medication Reconciliation (Appx D); Psychotropic 
Stewardship (Appx AB); Mealtime/IDDSI (Appx Z crosswalks); First Nations Partnership 
(Appx O); DPIA/Publication (Appx R/S); Transport (Appx AE); Switching (Appx M); Red-
Team (Appx U); Candour/Tribunal/Ombudsman (Appx AG); Police Integration (Appx AN); 
Financial Safety (Appx AH); Navigator/Foundational Supports Registry. 
 
Why this matters (and why it hasn’t worked) 
The 1990s IDS officer training and upper band hierarchical roles proved you can build a 
workforce that is practical, lawful and humane - ready for deinstitutionalisation and world-
best practice. Over the decades, titles multiplied while knowledge thinned. Today, “role” 
often outruns capability - from volunteers and support workers to support coordinators, senior 
public servants, planners, regulators and even the bench. People with cognitive disability pay 
the price in missed access, over-restrictive practice, and avoidable harm. This matrix restores 
the IDS spirit with our timely upgrade: licence by evidence, not by title - credit what’s solid, 
bridge the gaps, and prove competence and proficiency with OSCEs/EPAs. 
Fast take (read this first) 
• Map every person to a provisional IDC band (1-5), then issue a Bridging Plan. 
• Pre-practice bridges + at least one OSCE before solo work - no seniority waivers. 
• Use one RPL evidence pack (logs, attestations, short videos, certificates). 
• 30/90-day close-out on open gaps; use red-team scenarios if skill-slip appears. 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 320 
 
• Judiciary/NDIS/government leaders complete a Decision-Maker Fast Pack (bench-
cards + candour modules) with annual refresh. 
• Navigators replace/support legacy Support Coordination functions; they must sit on 
the IDC pathway (no “advice-only” carve-outs). 
• Map each Navigator to a provisional IDC band (target IDC-3) and issue a 
Navigator Fast Bridge Plan (AO-6N) on day one. 
• Pre-practice bridges (Access, Two-Key/Independence, Handover, 
Privacy/Publication, Candour, 72-hour basics) are mandatory before solo work. 
• Warm handover competence is verified via OSCE-HO and EPA-HO; document 
integrity and small-cell suppression are part of the exam. 
• Legacy Support Coordinators/PRCs cross-walk to Navigators via RPL + gap 
bridges; grand-parenting is time-boxed and safety-gated (AO-8N). 
 
IDC bands (plain) 
• IDC-1 Assistant: supports access & schedules under supervision. 
• IDC-2 Practitioner: runs everyday supports, records safely. 
• IDC-3 Lead: coordinates plans, books 72-hour reviews, coaches. 
• IDC-4 Specialist/Coach: complex cases, cross-agency interface, trains others. 
• IDC-5 Verifier/Calibrator: assesses OSCEs/EPAs, runs peer calibration (Appx V). 
 
A. Universal rules (apply to all titles) 
1. Licence by evidence (OSCE/EPAs) beats job title or pay grade. 
2. Access first (Appx N) is a pre-practice bridge for everyone. 
3. Independence & Two-Key. Navigators must demonstrate independence from 
provision (conflict screen) and, for consequential matters, log IPP pairing and 
timestamps; no Navigator may “single-key” a consequential decision. 
4. Least-restrictive + time-keeping (Appx A) beats “situational improvisation.” 
5. 72-hour learning (Appx B-C) after any incident/PRN-as-RP. 
6. First Nations protocols (Appx O) where relevant; privacy (Appx R/S) always. 
7. Switch-ready (Appx M): your competence and artefacts travel with the person. 
 
B. Equivalency & Bridging Matrix  -  Government, NDIS & Regulation 
Columns key: Provisional band (max) • RPL you must show • Pre-practice bridges 
(before solo) • Within 90 days • Assessment & checks 
1) Community & Frontline  
Role/title Band RPL 
evidence Pre-practice 90-day bridges Assessment 
Volunteer / Support 
friend 
IDC-
1 
Induction + 
referee 
Access prompts (N); 
Operational prompts 
(AK); Safeguarding 
basics 
Mealtime/IDDSI; 
Privacy/DPIA 
Buddy shifts; micro-
OSCE (OP-01/02) 
Disability Support 
Worker Cert III/IV 
IDC-
2 
Cert; 2 wks 
logs; 
supervisor 
note 
Access (N); Safety & RP 
basics (A); Transport safe 
(AE) 
72-hour review basics 
(B-C); Mealtime; Money 
safety (AH) 
OSCE-C ≤30d; 
OSCE-RP ≤60d 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 321 
 
Role/title Band RPL 
evidence Pre-practice 90-day bridges Assessment 
Team Leader / House 
or SIL Coordinator 
IDC-
3 
Roster, 
incident 
reviews 
Access (N); Least-
restrictive + timing (A); 
72-hour chair 
Candour basics (AG); 
First Nations (O); Finance 
oversight (AH) 
OSCE-RP + EPA-LR 
(chairs 1 review) 
Service/Operations 
Manager 
IDC-
3 
Site KPIs; 
audits 
As above + Owner 
Matrix/Escalation (Y) 
Publication/privacy 
checks (R/S); Red-team 
leadership (U) 
EPA-CAN 
(issues→actions) + 
calibration check (V) 
Peer/Lived-
Experience Worker 
IDC-
2 
Lived-
experience 
CV; refs 
Boundaries & privacy 
(R); Access prompts (N); 
RP basics 
Participation build (L); 
Money safety (AH) 
Buddy shifts ×6; 
OSCE-C 
 
 
2) Education & Youth 
Role/title Band RPL evidence Pre-practice 90-day bridges Assessment 
Teacher / Education 
Support / Youth 
Worker 
IDC-
2 
School plans; 
behaviour 
artefacts 
Access (N); Operational 
prompts (AK); RP basics 
Weekly Participation (L); 
Transport (AE) 
OSCE-C ≤30d; 
EPA-PART 
School Leader / 
SENCO 
IDC-
3 
Program plans; 
audits 
As above + 72-hour chair 
(B-C) 
Publication/privacy (R/S); 
First Nations (O) 
EPA-LR + 
calibration (V) 
 
 
3) Clinical & Practice 
Role/title Band RPL evidence Pre-practice 90-day bridges Assessment 
Registered/Enrolled Nurse IDC-
3 
Registration; med 
logs 
Least-restrictive + timing 
(A); Handover/Med-rec 
(D); PRN gate (AB) 
Access (N); 
72-hour chair 
OSCE-RP; 2 EPAs 
(HO, PRN) 
Allied Health 
(OT/SLP/Psych/SW/Physio) 
IDC-
3 
Registration/assoc; 
case notes 
Access (N) advanced; 
Mealtime (if relevant); 
RP (A) 
72-hour & 
Fade plan; First 
Nations 
OSCE-C + OSCE-
RP; EPAs (consent 
& participation) 
Behaviour Support Practitioner 
(credentialed) 
IDC-
4 Plans + outcomes 
Access (N) for BSPs; RP 
law & time-keeping (A); 
Candour pack (AG) 
Peer calibration 
(V); 
Dashboards (S) 
Calibrate 2 OSCE-
RP; 3 EPAs incl. 
tribunal-ready 
dossier 
Pharmacist (Psychotropic 
Stewardship) 
IDC-
3 Reg; DMM reviews 
PRN gate (AB); Access 
(N); Mealtime/IDDSI 
basics 
Candour (AG); 
Privacy (R) 
EPA-PRN + 
stewardship case 
Dentist / Oral Health Therapist IDC-
2 
Registration; clinic 
notes 
Dental desensitisation 
(AC); Access (N) 
72-hour 
review; First 
Nations 
EPA-DENT (ladder 
step) 
GP / Community Health 
Clinician 
IDC-
3 Reg; shared-care 
Access (N); RP 
hierarchy (A); Handover 
(D) 
Candour (AG); 
72-hour 
OSCE-RP (medical 
context) 
 
 
4) Justice, Police & Safety 
Role/title Band RPL 
evidence Pre-practice 90-day bridges Assessment 
Police/Justice 
Liaison (incl. 
custody) 
IDC-
3 
Scenario 
log; certs 
First-minute drill (AN); Access 
& least-restrictive (A/N); 
Transport (AE) 
72-hour review; 
First Nations co-
response (O) 
Joint OSCE with 
academy; 2 EPAs (scene 
+ handover) 
Court Support / 
Corrections / 
Security 
IDC-
2 
Logs; 
supervisor 
Access (N); Operational 
prompts (AK); RP basics 
Candour basics 
(AG) 
OSCE-C; EPA-CAN 
(intake) 
 
 
5) Government, NDIS & Regulation 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 322 
 
Role/title Band RPL evidence Pre-practice 90-day bridges Assessment 
NDIS/LAC Planner / 
NDIA Delegate IDC-3 Plans; decisions 
Access (N); Least-
restrictive 101 (A); 
Candour pack (AG) 
Publication/privacy 
(R/S); First Nations 
(O) 
EPA-CAN (decision 
with R&W); bench-
card quiz 
      
Navigator 
(Foundational 
Supports)  -  new 
appointee 
 
IDC-3 
(IDC-2 
provisional 
≤30 days 
max) 
CV; two referee 
contacts (one 
external); 4 weeks of 
case artefacts if prior 
role 
B-N 
Communication 
Access; B-A RP 
hierarchy + timer 
drill; B-D Handover 
& Med-Rec; B-R 
DPIA/Privacy & 
Publication 
(tiles/suppression); 
B-AG Candour pack 
(R&W + Matrix 
basics); Two-
Key/IPP 
independence check; 
Warm handover 
protocol 
B-BC 72-Hour 
Review & Fade 
Plan; B-L 
Participation build; 
B-O First Nations 
wording; 
Dashboard 
literacy (S-tiles) 
OSCE-C 
(community 
conversation), 
OSCE-HO (warm 
handover), mini-
OSCE PUB (safe 
notes/suppression); 
EPAs: EPA-HO, 
EPA-PART, EPA-
CAN (decision with 
R&W), EPA-PUB; 2 
external field 
observations; doc-
integrity spot check 
      
Navigator (transition 
from Support 
Coordination/PRC) 
IDC-3 
(IDC-2 
provisional 
≤30 days 
max) 
RPL pack: 
plans/brokerage 
history; case notes; 
two referees (one 
family/independent); 
integrity attestations 
Bridging deltas 
only: B-R 
DPIA/Publication; 
Two-Key/IPP 
screen; Warm 
handover bundle; 
B-AG Candour; B-
D Handover & Med-
Rec 
As above + 
Reasons & Matrix 
mini (H/I); S-tile 
literacy; Financial 
Safety 
Same as above; 
grand-parenting 
window ≤90 days to 
complete 
OSCE/EPAs; failure 
→ scope limits under 
Owner Matrix (Y) 
      
*Support Coordinator / 
Psychosocial Recovery 
Coach 
IDC-3 
(IDC-2 
provisional 
≤30 days 
max) 
Plans; brokerage 
history; case notes; 
two referee contacts 
(one external) 
Access (N); 
Operational prompts 
(AK); RP hierarchy 
+ time-keeping (A); 
Owner Matrix & 
Escalation (Y); 
Handover & Med-
Rec (D); 
Privacy/DPIA & 
Publication (R/S); 
Financial Safety 
(AH); Switching 
(M); Candour 
basics (AG) 
72-hour basics & 
Fade plan (B-C); 
Reasons & Matrix 
mini (H/I); First 
Nations wording 
(O); Dashboard 
literacy (S) 
OSCE-C 
(community 
conversation) and 
OSCE-HO 
(handover); EPAs: 
EPA-PART 
(community role), 
EPA-HO (handover), 
EPA-CAN (decision 
with R&W), EPA-
PUB (safe 
tile/suppression 
note); 2 external 
field observations; 1 
S-8 change-note 
draft; documentation 
integrity check 
      
Regulator/Commission  
-  Complaints & 
Investigations 
IDC-3 Case files 
Candour (AG); 
Access (N); 
R&W/Matrix (H/I) 
Publication/privacy 
(R/S) 
EPA-CAN + 
calibration (V) 
      
Guardianship/OPA 
Officer IDC-3 Files; appearances 
Access (N); 
Candour (AG); 
Least-restrictive (A) 
First Nations (O); 
Publication (R/S) 
EPA-CAN (orders & 
safeguards) 
      
Tribunal 
Registrar/Member / 
Judiciary† 
IDC-3 Bench exp.; PDs 
Decision-Maker 
Fast Pack: R&W + 
Matrix (H/I); Access 
(N); small-cell 
privacy (S/R) 
72-hour learning 
lens; First Nations 
wording 
Bench-card OSCE 
(applied tests) + 
yearly refresh 

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Role/title Band RPL evidence Pre-practice 90-day bridges Assessment 
      
Dept. 
Executives/Directors / 
Board 
IDC-3 Portfolios; KPIs 
Message House & 
Candour (AM/AG); 
Owner Matrix (Y); 
Dashboards (S) 
Privacy/DPIA (R); 
Red-team 
leadership (U) 
Governance OSCE 
(tile reading + 
actions) 
†Decision quality pack: applied tests, weights, contradictions, suppression, and accessible 
participation  -  not clinical up-skilling. 
*Legacy positions; This role is transitioning to Navigator; use AO-6N Fast Bridge and AO-
8N Grand-parenting letter. IDC-2 provisional is capped at 30 days. 
 
 
 
6) Corporate & Enablers 
Role/title Band RPL 
evidence Pre-practice 90-day bridges Assessment 
Finance/Admin handling 
client funds 
IDC-
2 
Role desc.; 
audit 
Financial safety (AH); 
Access (N) Publication/privacy EPA-FIN 
(exceptions down) 
Procurement / ICT / Data & 
Analytics 
IDC-
2 
Role desc.; 
specs 
AT/AAC spec (AF); 
Privacy/DPIA (R); 
Publication (S) 
Switching (M); Audit 
(T) 
EPA-PUB (safe 
tiles) + hash trail 
Communications/Media IDC-
2 
Releases; 
logs 
Access (N); Media plan 
(AM); Small-cell checks 
(S/R) 
Candour interface 
(AG) 
EPA-PUB 
(correction notes) 
Insurance/Legal IDC-
3 
Notices; 
claims 
Candour (AG); DPIA (R); 
Owner Matrix (Y) Red-team (U) EPA-CAN (first-
notice quality) 
 
 
C. Bridging modules (menu) 
Code Module Hours OSCE/EPA link 
B-NAV Navigator role, independence & conflict screen (IPP) 1.5 OSCE-HO, EPA-HO 
B-WH Warm handover bundle (artefact + contact + booked/kept) 1.0 OSCE-HO, EPA-HO 
B-PUB-N Publication & small-cell suppression for Navigators 1.0 mini-OSCE PUB, EPA-PUB 
B-CAN-N Candour with families (plain-English R&W / Matrix mini) 1.0 EPA-CAN 
B-DL Dashboard literacy (S-tiles, reading & notes) 0.75 EPA-PUB 
B-N Communication Access & teach-back 2-4 OSCE-C 
B-A Safety & Restrictive Practices + timer drill 3 OSCE-RP 
B-BC 72-Hour Review & Fade Plan 2 EPA-LR 
B-D Handover & Medication Reconciliation 1.5 EPA-HO 
B-AB Psychotropic Stewardship & PRN gate 2 EPA-PRN 
B-L Weekly Participation & backups 1.5 EPA-PART 
B-ME Mealtime/IDDSI safety 1.5 EPA-MEAL 
B-R DPIA/Privacy & Publication checks 1 EPA-PUB 
B-O First Nations cultural safety & wording 1.5 EPA-FN 
B-AE Transport securement & distress stops 1 EPA-TR 
B-AG Candour pack (R&W + Matrix) 1.5 EPA-CAN 
B-AK Operational prompts in practice 1  -  

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D. RPL (Recognition of Prior Learning)  -  evidence pack 
• RPL-NAV bundle: AO-RPL form; two referees (one external/family); 2 de-
identified reasons blocks; 1 warm-handover artefact; 1 documentation-integrity 
sample (e-receipt + roster link). 
• Credit rules: documented warm handover experience and Two-Key/IPP familiarity 
can credit B-WH/B-NAV; no credit for Publication/suppression without a passed 
mini-OSCE PUB. 
• Time-box: ≤90 days to close all gaps; unresolved → scope restriction (Owner Matrix 
Y) until completed. 
• AO-RPL form + supervisor attestation 
• Short skills video (2-4 min) (consent/DPIA) 
• Two case notes showing access + least-restrictive decisions 
• Licences/registrations & CPD 
• Referee calls (one internal, one external) 
Outcome: credit granted + dated Bridging Plan with OSCE/EPA bookings 
 
E. Supervision, calibration & skill-slip 
• Navigators at IDC-2 provisional require 100% buddying on consequential 
handovers until OSCE-HO passed. 
• Any missed 72-hour review, absent second key on consequential action, or 
publication without suppression → immediate red-team micro-scenario + re-
OSCE (mini-OSCE PUB / OSCE-HO). 
• At least one external observation (non-line reviewer) within first 30 days. 
• Before sign-off: IDC-1 → 100% close; IDC-2 → 25-50%; IDC-3 → case review; 
IDC-4/5 → peer review. 
• Peer calibration 6-monthly (Appx V). 
• Skill-slip (missed access, unsafe restraint, late review) → red-team micro-scenario 
+ targeted coaching + re-OSCE if needed. 
 
F. Quick placement guide (use this to assign today) 
 
Stream Typical title → IDC band 
House/SIL & 
community 
Navigator (Foundational Supports) = IDC-3 target (IDC-2 provisional ≤30d); pre-practice B-
NAV/B-WH/B-R/B-AG/B-D; OSCE-HO booked ≤30d. 
Team Leader = IDC-3; Practice Lead / Complex Case Coord = IDC-4; Program Educator (field) 
= IDC-4; Director of Practice Quality = IDC-5 
  
Behaviour support Senior BSP = IDC-4; Principal BSP / BSP Clinical Governance Lead = IDC-5 
Clinical (RN/allied) Clinical Nurse Consultant / Clinical Educator = IDC-4; Principal Clinician / Allied Clinical Lead 
(program-wide) = IDC-5 
Health interfaces Hospital/ED Interface Lead = IDC-4; Service-wide Handover/Med-rec Verifier = IDC-5 

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Stream Typical title → IDC band 
Communication & 
culture 
AAC Lead; First Nations Practice Lead = IDC-4; Cultural Calibration Lead (program-wide) = 
IDC-5 
Systems, data, 
publication 
Publication Steward (channel) = IDC-4; Principal Publication Steward / Privacy Gatekeeper = 
IDC-5 
Rural/paeds Micro-hub Lead / Tele-OSCE Proctor = IDC-4; Rural/Paeds Lead Examiner = IDC-5 
Governance & 
education OSCE Station Lead = IDC-4; Lead OSCE Examiner / Calibration Lead = IDC-5 
 
 
 
IDC-4  -  Specialist / Coach 
Core: handles complex cases across interfaces, coaches others, and leads practice uplift. 
Must still meet all IDC-3 requirements, plus coach/examine in their specialty. 
What IDC-4s do (minimum) 
• Take complex referrals, run cross-agency plans, and coach IDC-1-3. 
• Chair 72-hour reviews and ensure fade plans exist where needed. 
• Run targeted bridges (B-modules) and observe EPAs for staff. 
• Proctor tele-OSCEs or in-person stations; contribute to item review. 
IDC-4 must have: 
• Passed full rOSCE circuit at exemplar level in their specialty station(s). 
• Observed and signed ≥20 EPAs for others (with feedback artefacts). 
• Chaired ≥3 72-hour reviews and produced a fade-plan insert where indicated. 
• Delivered ≥2 bridging modules (B-codes) and logged outcomes. 
IDC-5  -  Verifier / Calibrator 
Core: assures competence across the program - examines OSCEs, signs EPAs, runs 
calibration, and protects provenance/public transparency. 
What IDC-5s do (minimum) 
• Double-mark OSCEs; run calibration and publish kappa/standard-setting notes. 
• Sign final EPA panels (with at least one external observation). 
• Oversee complaint-independent sampling and publish cohort tiles (S-pack). 
• Guard change control: S-8 notes, T-pack hashes, and suppression discipline. 
IDC-5 must have: 
• Led ≥2 OSCE calibration events; kappa ≥0.6 on sample double-ratings. 
• Chaired ≥3 EPA panels (with an external). 
• Published ≥1 S-8 visible change note and T-pack hash manifest tied to an assessment 
cycle. 

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• No unresolved conflicts of interest; externality demonstrated each quarter. 
Not in scope (important) 
• Judiciary/Tribunal/OPA/Regulator leadership complete the Decision-Maker Fast 
Pack and bench-card OSCE, but that is decision-quality credentialing, not IDC 
licensure. They don’t hold IDC-4/5 unless they are also appointed within the IDC 
program’s assessment/governance structure. 
 
Who audits the auditors  -  supervision chain 
Goal. Make audits trustworthy by adding independent eyes, rotation, and public traceability. 
Titles don’t trump evidence. 
Four lines of assurance (who checks whom) 
1. First line  -  Practice supervision (case level) 
o Who: IDC-4 (Specialist/Coach) supervising IDC-1-3 on live work. 
o What: observes EPAs, runs 72-hour reviews, signs AO/AA packs. 
o Limits: cannot be the only assessor for their own supervisee’s summative 
decision. 
2. Second line  -  Program verification (meta-audit) 
o Who: IDC-5 Verifier/Calibrator (not in the supervisee’s reporting line). 
o What: double-marks OSCE samples; re-checks EPA evidence; reviews 
documentation integrity & privacy. 
o Rules: ≥20% of each supervisor’s audits are re-audited each quarter; kappa 
≥0.6 target; publish calibration note. 
3. Third line  -  Independent Quality & Audit Committee (org-level) 
o Who: Chair external to operations; members include an external IDC-5, a 
Privacy/DPIA lead, and a First Nations advisor (when relevant). 
o What: approves the yearly Audit Plan, examines trends, and signs S-8 visible 
change notes for systemic fixes. 
o Powers: can trigger Red-Team (U) scenarios and impose G-pack sanctions 
(Notice → CAP → Hold → Probation). 
4. Fourth line  -  External assurance 
o Who: External assessor pool (contracted IDC-5s), partner hospital educators, 
or regulator-appointed reviewers. 
o What: random shadowing, tele-OSCE proctor checks, file-vs-field matches. 
o Output: short Public Summary (non-PII) + T-pack hashes. 
Independence & rotation rules 
• No single-line sign-off: any summative decision must include either (a) an external 
observation, or (b) an IDC-5 not in the line. 
• Rotation: supervisors rotate every 12 months across teams or have a paired co-
reviewer for independence. 
• Conflict declarations: recorded in the audit record; conflicted reviewers cannot sole-
sign EPAs/OSCE outcomes. 

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Meta-audit cadence & scope 
• Quarterly: re-audit ≥20% of each supervisor’s audits (stratify by risk: restraint 
minutes, PRN-as-RP, ED/police contact). 
• Half-yearly: observe each supervisor in the field at least once; verify their timing 
discipline on 72-hour reviews. 
• Annually: full calibration day (double-rating OSCE videos/cases); publish kappa 
and any scoring drifts. 
Evidence & provenance (must attach) 
• T-1/T-3 events for: audit start/stop, reviewer identity, conflicts, outcomes, 
remediation tasks, and hash manifest. 
• S-8 note if rules or denominators change (non-PII; link to Audit Plan item). 
• Owner Matrix (Y) entry naming the audit owner, due date, escalation path. 
Escalation (who the supervisor answers to) 
• If a supervisor fails an independence or safety check: 
o Immediate pause on their summative sign-offs. 
o Red-Team micro-scenario focused on the failure mode (U-pack). 
o Re-observation by a different IDC-5; CAP (G-2) with time-boxed fixes. 
o Repeat breach → refer to Sanctions Ladder (G-pack) and publish a short S-8 
note. 
Participant voice (without complaints) 
• After audited contacts, send a two-question micro-survey (access/clarity; on-time 
actions). 
• Results feed dashboard tiles (non-PII) reviewed by the Audit Committee. 
Rural/remote & paediatric variants 
• Use tele-observation plus at least one in-person co-review yearly per supervisor. 
• Paediatric audits include school inclusion and paeds mealtime checks. 
 
Quick matrix  -  “who supervises the supervisor” 
Auditor role Who checks them How often Independence guard 
IDC-4 Practice 
Supervisor IDC-5 Verifier/Calibrator Quarterly re-audit ≥20% + field 
shadow half-yearly 
Different reporting line; conflict 
recorded 
IDC-5 
Verifier/Calibrator 
Independent Quality & Audit 
Committee 
Quarterly trend review; annual 
calibration day 
External member on committee; 
kappa published 
Audit Committee External assessor/regulator Annual program review or spot 
audit 
Public summary + S-8/T-pack 
trail 
 
 
 
Measures (internal; some publishable) 

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• Time from hire/role change → safe solo (median days) 
• navigator_warm_handover_rate (S-Q06) ↑ after AO-6N completion. 
• r2r_on_time_rate (S-P03) stable/improving where Navigators support contested 
matters. 
• doc_integrity_score (S-P06) ↑ where Navigator notes meet mini-OSCE PUB 
standard. 
• OSCE first-pass rate (%) by title family 
• 90-day bridge completion (%), open-gap count 
• Incidents linked to access failure (↓) 
• 72-hour reviews on time (↑) 
• Participation tiles improve post-bridge (Appx S) 
 
Micro-scenarios (worked) 
• Support Coordinator: Once pre-practice bridges met; mini-OSCE (OSCE-HO) sat 
before any solo work. AO-6 Fast Pack used on first live case; external observation 
#1 scheduled within 3 weeks. Quarterly complaint-independent audit randomly 
selects this case: consent & access present, reasons table solid, S-8 draft logged after 
service change. One PRN-as-RP alert the next month triggers automatic 72-hour 
review booking and a red-team micro-scenario drill; remediation completed and re-
observed. Dashboard shows external_observation_rate ↑ and 
30d_bridge_completion_pct = 100%. 
 
• Navigator onboarding: Day 1 mapped to IDC-3 (provisional IDC-2). Pre-practice 
bridges completed (B-NAV, B-WH, B-R, B-AG, B-D). OSCE-HO passed at day 19; 
mini-OSCE PUB at day 24. Two external observations logged. First quarter shows 
navigator_warm_handover_rate ↑, doc_integrity_score ↑, and r2r_on_time_rate 
steady. One missed suppression note triggers a red-team drill; remediation 
documented; subsequent audit clean. 
 
• NDIA delegate: Completes Candour + Access modules and bench-card OSCE. First 
three decisions run through a 10-minute audit (from the Oversight Pack) even 
without complaints. Outputs now include an R&W table, contradiction log IDs, and a 
suppression note where small-cell risk exists. One late action (>7 days) is escalated 
via Owner Matrix (Y); a short S-8 note explains the fix-forward change. 
 
• Senior registrar: Uses Decision-Quality Fast Pack + small-cell checks. Two 
independent file-vs-field observations are booked per the Oversight Pack. Hearing 
notes shift from narrative to evidence-weighted with clear legal tests; 72-hour 
cadence visible on the calendar. After a missed Tier-0 cue in a sampled case, a red-
team micro-scenario is run; registrar passes a targeted re-OSCE station the 
following week. 
 
• Peer worker: Completes Access + boundaries + Money safety bridges; OSCE-C 
booked and passed within 3 weeks. Supervisor logs 6 buddy shifts; one external 
observation checks documentation integrity and privacy habits. Participation sessions 
increase; audit sampling of two cases shows clean consent notes and no privacy 
leaks; no incidents recorded. 
 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 329 
 
• BSP (Behaviour Support Practitioner): Adds time-keeping and candour modules; 
all restraint minutes now start/stop-timed and route to 72-hour reviews. Tribunal 
dossier is accepted without defect; peer calibration is logged (Appx V). Oversight 
sampling finds denominator drift in a published tile; BSP files a visible S-8 change 
note and updates the plan; restraint minutes trend down quarter-on-quarter. 
 
Quick scripts 
• To a candidate: “We’ll credit what you already know. You’ll bridge the gaps and 
pass an OSCE before you work solo.” 
• To a manager: “Map to a provisional band today, book 3 bridges, OSCE ≤30 days, 
and choose 2 EPAs that prove change.” 
• To a Navigator: “We’ll credit what you already know. You’ll complete Access, 
Handover, Candour and Publication bridges, then pass OSCE-HO and a quick 
publication safety check before solo work.” 
• To a family: “Your Navigator must log the warm handover, book and keep the first 
appointment, and record plain-English reasons where decisions affect you.” 
• To leaders/judiciary: “This pack lifts decision quality: clear tests, evidence weights, 
contradictions resolved, privacy safe.” 
 
AO templates list (Appendix AA) 
• AO-1 Equivalency Matrix (CSV)  -  title family → provisional band → bridges → 
assessments 
• AO-2 Individual Bridging Plan (auto-dated tasks + owners) 
• AO-3 RPL Evidence Checklist & Supervisor Attestation 
• AO-4 OSCE Booking Sheet & Results Log (mini/full; safety stations flagged) 
• AO-5 EPA Pack (INT, EVID, FF-VER, PRN, MEAL, HAND, CONS, PRIV, 
R&W/IRC, PUB, RURAL, SWITCH) 
• AO-6 Support Coordinator Decision-Quality Fast Pack 
• AO-6N Navigator Fast Bridge Pack (checklist + module links + booking sheet) 
• AO-7 SC Complaint-Independent Oversight Pack 
• AO-7N Navigator Oversight Pack (complaint-independent sampling + external 
observation form) 
• AO-8 Grand-parenting Letter (time-boxed equivalency with safety gates) 
• AO-8N Grand-parenting Letter  -  Navigator Transition (time-boxed, safety-
gated) 
• AO-9 Bench-Cards  -  Decision-Maker Fast Pack (R&W, Matrix, small-cell, 
applied tests) 
• AO-9N Bench-Cards for Navigators (Two-Key/IPP, warm handover, suppression 
quick checks) 
• AO-10 30/90-Day Review Form (gap close-out; status colours) 
• AO-11 Skill-Slip Red-Team Scenario Builder (trigger → scene → test → 
remediation) 
• AO-12 Title→Band Mapper (Quick Intake) (role → provisional band → pre-
practice bridges) 
• AO-13 Governance OSCE (tile reading + actions; leaders/board) 
• AO-14 Annual Currency Tracker (OSCE/CPD due list; alerts) 

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• AO-15 External Calibration Pack (double-marking sheets; kappa log) 
• AO-16 Rural & Paediatric Variant Kit (tele-OSCE, satellite hub checklist, paeds 
stations) 
• AO-17 Publication & S-8 Hook (how bridging artefacts surface as non-PII change 
notes) 
• AO-18 IDC Audit Plan (with risk-weighted sampling math) 
 
Summary companion. Decisions rely on the governing sections named in IDC 
Curriculum & OSCEs, Safety & Restrictive Practices, Communication Access, 72-Hour 
Review, Handover/Medication, Psychotropic Stewardship, Mealtime/IDDSI, First 
Nations Partnership, Transport, DPIA/Publication, Owner Matrix & Escalation, Red-
Team and Candour/Ombudsman/Tribunal protocols. 
 
Appendix AO.1  -  DSC Equivalency & Bridging Matrix 
Licensing regulators by evidence, not job title. 
Owner: DSC  -  Workforce & Capability (with Governance & Legal Liaison) 
Interfaces: Candour by Template & AG.1 (Tribunal/OPA/Ombudsman & DSC companion); 
Owner Matrix & Escalation (Appx Y); Reasons & Weighting / Contradiction Matrix (Appx 
H/I); DPIA & Publication (Appx R/S); Audit Log (Appx T); E-Receipts & Cross-Checks 
(Appx E/F); Dashboards (Appx S); Red-Team (Appx U); IDC Curriculum/OSCEs (Appx Q); 
Communication Access (Appx N); First Nations Partnership (Appx O); Evaluation Access 
(Appx W). 
 
Why this matters (and why it hasn’t worked) 
Regulatory teams are strong generalists, but access practice, evidence-weighting and privacy 
vary. That creates late or uneven notifications, unweighted dossiers, small-cell risk, and case 
drift. A DSC must model the standard: access first, one evidence set (R&W + Matrix), 
least-restrictive thinking, and publication the public can check and trust. 
 
Fast take (read this first) 
• Provisional IDC banding (IDC-2…IDC-4) for DSC roles on day one; no solo 
practice for complaint intake or investigations until pre-practice bridges + rOSCE 
(regulatory OSCE) are passed. 
• One evidence set everywhere (R&W + Matrix + hashes) shared across 
tribunal/ombudsman/DSC - no rewrites. 
• S0-S3 triage windows are met; fix-forward runs in parallel (AG.1). 
• Small-cell & cultural safety checks on every outbound line. 
• 6-monthly calibration across regions to keep decisions aligned. 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 331 
 
 
A) Roles → Bands → Bridges (copy-ready) 
Columns: Provisional IDC band (max) • RPL you must show • Pre-practice bridges (before 
solo) • Within 90 days • Assessment (rOSCE/EPA) 
DSC role Band RPL evidence Pre-practice 90-day bridges Assessment 
Complaints/Intake 
Officer 
IDC-
2 
Prior 
complaints/call-
centre logs; 
supervisor note 
Access prompts (N); 
S0-S3 triage (AG.1); 
Candour intake 
(plain capture); 
Privacy basics (R) 
First Nations wording 
(O); 
Publication/suppression 
intro (S) 
rOSCE-Triage 
(classify + pack stub 
≤60 min); EPA-
CAN-INT (clean 
intake) 
Case Triage Lead IDC-
3 
Triage decisions; 
queue stats 
Above + 
R&W/Matrix (H/I); 
Owner Matrix (Y) 
Dashboards (S); Red-
team leadership (U) 
rOSCE-Weigh (top-
6 evidence table + 
Matrix); EPA-TRI-
OT (on-time rate) 
Investigator 
(desk/field) 
IDC-
3 
Case files; 
interview notes 
Accessible interview 
(N/AAC/Auslan); 
Least-restrictive 
lens (A); DPIA on 
collection (R) 
Matrix deep dive; Family 
plain-summary skills 
rOSCE-Interview 
(AAC scenario); 
rOSCE-Weigh; 
EPA-EVID 
Clinical Adviser 
(Pharmacist/SLP/OT 
etc.) 
IDC-
3 
Registration; 
reviews/audits 
Psychotropic 
stewardship (AB) or 
Mealtime/IDDSI (as 
relevant); Candour 
Publication/privacy 
(R/S); tribunal interface 
(AG) 
rOSCE-Clin (advice 
note with RP timing); 
EPA-PRN/MEAL 
Field 
Inspector/Auditor 
IDC-
3 Site audits; CAPs 
Access first (N); RP 
timing & logs (A/T); 
E-receipt integrity 
(E/F) 
Fix-forward verification; 
First Nations protocol 
(O) 
rOSCE-Audit 
(finding→control); 
EPA-FF-VER 
Legal/Decision Writer IDC-
3 Orders/decisions 
R&W/Matrix (H/I); 
Applied tests; 
Small-cell checks (S) 
Plain-English 
summaries; Cultural 
wording (O) 
rOSCE-Decision 
(orders + 
safeguards); EPA-
CAN-DEC 
Data & Analytics IDC-
2 
Dashboards/SQL; 
QA notes 
Suppression rules 
(S); Audit hashes 
(T); Access context 
(N) 
Tile codebook; mis-ID 
risk patterns 
rOSCE-Publish 
(safe tile); EPA-PUB 
Publication/Comms IDC-
2 
Releases; media 
logs 
Media plan (AM); 
Small-cell/consent 
(S/R); Candour 
framing (AG) 
First Nations co-release 
(O) 
rOSCE-Publish; 
EPA-CORR 
(corrections) 
Panel Chair/Reviewer IDC-
4 Hearings/appeals 
R&W/Matrix; 
Access & 
interpreters (N); 
Applied tests 
Calibration lead (V); 
Ombudsman/AG routing 
rOSCE-Panel 
(applied tests under 
time); EPA-CAL-
LEAD 
Program 
Manager/Team Lead 
IDC-
3 
KPIs; 
improvement logs 
Owner Matrix (Y); 
AG.1 cadence; 
Dashboards (S) 
Red-team routines; 
Evaluation access (W) 
EPA-RUN (S0-S3 
on time; close-outs) 
Gate: No solo complaint handling or field investigation until pre-practice bridges + first 
rOSCE are passed. 
 
B) Bridging modules (DSC set) 
Code Module Hours rOSCE/EPA link 
B-AG.1 S0-S3 DSC triage & cadence 1.5 rOSCE-Triage, EPA-TRI-OT 
B-H/I Evidence & Weights + Contradiction Matrix 2 rOSCE-Weigh, EPA-EVID 

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Code Module Hours rOSCE/EPA link 
B-N-INV Accessible interviewing (AAC/Auslan/PECS) 2-3 rOSCE-Interview 
B-A Least-restrictive lens & time-keeping 2 rOSCE-Decision 
B-R/S Privacy/DPIA + small-cell suppression 1.5 rOSCE-Publish, EPA-PUB 
B-FF Fix-forward verification & CAPs 1 EPA-FF-VER 
B-O First Nations protocols & wording 1.5 Panel/Publish sign-off 
B-T Audit & provenance (hashes, chain-of-custody) 1 All rOSCEs 
B-AM Public narrative & crisis comms 1 EPA-CORR 
 
C) RPL (Recognition of Prior Learning)  -  regulator version 
• AO.1-RPL form + 2 case examples; one must include access supports. 
• Short skills video (2-4 min): intake or interview using AAC/interpreter 
(consent/DPIA). 
• Anonymised R&W table + Matrix from a real/retro case. 
• Referees: one internal, one external/independent. 
• Outcome: credit granted + dated Bridging Plan with rOSCE bookings. 
RPL credit rules (quick): 
• Demonstrated S0-S1 triage with clean intake → credit B-AG.1 theory only (rOSCE 
still required). 
• Prior accessible interviewing → credit B-N-INV hours after skills video; rOSCE-
Interview still required. 
• Prior publication responsibilities without documented suppression → no credit for 
B-R/S until rOSCE-Publish passed. 
 
D) Bridging Plans (templates & cadence) 
Plan contents (one page): role → provisional band; RPL credits; pre-practice bridges 
(dates/bookings); 90-day bridges; rOSCE/EPA schedule; supervisor + second reviewer; risks 
& mitigations. 
Cadence: 
• Day 0-5: RPL review; plan issued and booked. 
• ≤30 days: complete all pre-practice bridges + first rOSCE (role-specific). 
• ≤90 days: close remaining bridges; sit any remaining rOSCE/EPA. 
• Slippage: owner escalates via Owner Matrix (Y); scope limits may apply. 
 
E) Supervision, calibration & “skill-slip” 
• Before sign-off: Intake IDC-2 → 100% co-review; Investigator IDC-3 → joint plan 
+ first two interviews shadowed. 
• Calibration: 6-monthly cross-region case rating using the same R&W pack (Appx 
V). 

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• Skill-slip triggers (missed access, small-cell breach, late S0/S1) → immediate red-
team micro-scenario + targeted bridge + re-rOSCE. 
 
F) Measures (internal; some publishable) 
• S0/S1 on-time notifications (%) 
• Intake completeness (EPA-CAN-INT pass rate, %) 
• rOSCE first-pass rate by role (%) 
• Small-cell/privacy defects (count)  -  trend ↓ 
• Fix-forward verified on time (%) 
• Complaint re-work / tribunal returns for defect (%)  -  trend ↓ 
• Interpreter/Auslan/AAC provided at interviews (%)  -  trend ↑ 
(Public metrics follow Appendix S suppression/rounding.) 
 
G) Micro-scenarios (worked) 
• S0 restraint outside plan: Intake triages S0; 60-min pack with R&W top-6 + 
Matrix; immediate controls listed; 72-hour review booked; rOSCE-Triage sign-off 
for new officer. 
• Publication risk: Analyst proposes a map with small cells; Comms applies 
suppression; rOSCE-Publish passed; safe release with change note. 
• Conflicting accounts: Investigator runs accessible interview with AAC; Matrix 
prefers body-worn clip over hearsay; decision writer adds least-restrictive 
safeguards; Ombudsman notes quality. 
 
H) Where to get help / Artefacts & Templates 
• AO.1-1 Role→Band mapper (DSC) 
• AO.1-2 Bridging Plan (DSC) with rOSCE schedule 
• AO.1-3 rOSCE rubrics (Triage, Interview, Weigh, Decision, Publish) 
• AO.1-4 EPA pack (INT, EVID, FF-VER, PUB, RUN) 
• AO.1-5 Intake & Interview checklists (access, privacy, First Nations wording) 
• AO.1-6 Calibration kit (shared R&W case + scoring guide) 
• AO.1-7 Red-team scenario builder (regulator edition) 
 
Summary companion. DSC capability is licensed by evidence: map to a provisional band, 
bridge fast, prove it in rOSCE/EPA, and publish safely. Use one evidence set (R&W + 
Matrix + hashes), keep triage on time, and treat privacy & cultural safety as non-
negotiable parts of quality. 
 
 

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Appendix AO.2  -  Tribunal Practice Note (Brief): Two-Key Guardianship 
Owner: Tribunal/Registry (with OPA/OPG liaison and DSC Secretariat) 
Interfaces: Shared Decision Standard (Two-Key); Reasons & Weighting (Appendix H); 
Contradiction Matrix (Appendix I); Independent-Reasoning Certificate (Appendix J); 72-
Hour Review (Appendix B/C); Truth-by-Design/e-Receipts (Appendix E/F); Publication & 
Tiles (Appendix S/AL); Audit Log (Appendix T); First Nations Partnership (Appendix O); 
Communication Access (Appendix N); Owner Matrix (Appendix Y) 
 
Why this matters (and why it hasn’t worked) 
High-impact orders still hinge on desk files, single-actor findings, or late reasons. Families 
experience opacity; frontline practice diverges from the record. Two-Key makes 
consequential decisions fast and safe - if independence, evidence weights, and review 
cadence are visible on the page. This note standardises what must be recorded, and adds a 
light equivalency/bridging pathway so registrars and members apply the method 
consistently. 
 
Fast take (read this first) 
• No single-actor orders in consequential matters: record second key, 
independence/IPP check, and timestamps. 
• Use the R&W short form with a 0-4 probative weight for each item; resolve 
conflicts in the Matrix (IDs on page). 
• Tier-0 emergency decisions act first, then 72-hour review with fade/next-steps. 
• Small-cell suppression for any publication; log the audit hash. 
• Bench-ready: new/returning decision-makers follow a Decision-Quality Fast Bridge 
(below) with an RPL check and a short bench OSCE. 
 
Scope 
Applies to consequential orders/endorsements (liberty/residence, restrictive practices incl. 
psychotropics, high-risk health consent, discharge to new setting, high-value changes). 
Covers interim (Tier-0) and standard hearings; works with DSC file↔field verification where 
facts are contested. 
 
Two-Key Decision Record (R&W short form) 
Complete in every consequential matter (interim and final). Keep to 1-2 pages plus annexes. 
• Decision class; why now; alternatives tried; least-restrictive test. 
• Evidence table: Source → Probative weight (0-4) → Why (≤25 words; integrity 
hooks if used). 
• Applied tests: rights; least-restrictive; lawfulness; proportionality; candour/integrity; 
privacy/suppression. 
• Will & preferences: plain words; method (SDM/AAC/interpreter; BIWP if used). 

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• Co-signers: roles, IDs, independence screen (IPP), timestamps (start/stop). 
• Outcome; safeguards/conditions; review date; publication note (what goes public; 
suppression tag). 
• Links: R&W full table (H); Matrix row IDs (I); IRC tick (J); audit-log hash (T). 
Evidence table (example headings): EvID | Description | Source | Date/Time | Weight (0-4) 
| Why (≤25w) 
 
Will and Preferences Note (insert) 
• Method used: SDM/BIWP/AAC/interpreter; who assisted; how 
comprehension/communication were supported. 
• Person’s priorities/concerns in their words (or best evidence of will/preferences). 
• Dignity-of-risk considered; agreed supports and fade/expiry rules (if any). 
 
Tier-0 Log & 72-Hour Review (for emergency pathways) 
• Trigger; immediate action; restraint/sedation minutes; outcome. 
• 72-hour review: attendees; alternatives considered; least-restrictive re-test; 
fade/next-steps plan; learning points logged; date of next review. 
• Outputs: updated R&W short form; Matrix updates; reasons digest; audit hash; 
publication note. 
 
DSC Calibration Memo (Two-Key)  -  (for contested/complex matters) 
• File vs field checks: second-key independence; rotation; R&W quality; will & 
preferences fidelity. 
• Variances; corrective actions; publication note (non-PII); integrity hooks checked 
(e-receipt/roster↔claim/audit-log). 
• Memo feeds Owner Matrix (Y) and tiles (S-Q02, S-P06). 
 
Equivalency & Bridging (for Tribunal roles) 
Goal: credential decision-quality skills quickly (not clinical content). Titles don’t exempt 
anyone from the method. 
Roles → Provisional band → Bridges → Assessment 
Columns: Band (DQ) · RPL you must show · Pre-practice bridges (before sitting) · 
Within 90 days · Assessment 
Tribunal role 
Band 
(Decision-
Quality) 
RPL evidence Pre-practice bridges 
(before sitting) 90-day bridges Assessment 
Registrar (case 
manager/ADR) DQ-2 
2 recent 
bundles 
showing 
B-H/I-DQ (R&W+Matrix 
for registries); B-N (Access 
B-LR (least-
restrictive & 
review cadence); 
Bench-OSCE-R (short-
form compile); EPA-

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Tribunal role 
Band 
(Decision-
Quality) 
RPL evidence Pre-practice bridges 
(before sitting) 90-day bridges Assessment 
issues, weights 
table, Matrix 
refs 
& interpreters); B-S/T 
(Suppression + audit hash) 
B-PUB 
(publication 
notes) 
DQ-REG (on-time 
bundle) 
      
Member 
(decision-maker) DQ-3 
3 decisions 
with tests 
applied; 1 
appeal upheld 
B-H/I-DQ; B-LR; B-CAN 
(plain-English reasons); B-
IPP (Two-
Key/independence) 
B-72H (Tier-
0→72h); B-FN 
(First Nations 
wording) 
Bench-OSCE-M 
(applied tests under 
time); EPA-DQ-M 
(findings→actions) 
      
Senior 
Member/Deputy 
President 
DQ-4 
5 decisions 
incl. contested 
facts; 1 
published 
reasons model 
As for Member + B-CAL 
(panel calibration & dissent 
handling) 
B-PUB-ADV 
(small-cell edge 
cases); B-RED 
(red-team drill) 
Bench-OSCE-S (panel 
lead & dissent); EPA-
DQ-LEAD 
Bands (Decision-Quality only): 
• DQ-2: compiles compliant short-form; understands suppression/audit. 
• DQ-3: applies tests; resolves contradictions on the record; manages Two-Key & 72h 
loop. 
• DQ-4: leads panels; calibrates peers; publishes model reasons; guards privacy at 
scale. 
 
Decision-Maker Fast Bridge (plan template) 
Who: any registrar/member new to Two-Key, or returning after >12 months. 
Plan contains: role → DQ band target; RPL credits; pre-practice bridges (dates/bookings); 
90-day bridges; Bench-OSCE/EPA schedule; second reviewer; risks & mitigations. 
Cadence: 
• Day 0-5: RPL review; plan issued and scheduled. 
• ≤30 days: complete pre-practice bridges + Bench-OSCE (role-specific). 
• ≤90 days: close remaining bridges; sit EPA(s). 
• Slippage: escalate via Owner Matrix (Y); may limit listing duties until complete. 
Bridge module keys (non-clinical): 
• B-H/I-DQ: R&W/Matrix for tribunal writing (weights 0-4; ≤25-word why). 
• B-IPP: Two-Key independence & IPP timestamps; conflict screen. 
• B-LR: Least-restrictive & review triggers (expiry/fade). 
• B-72H: Tier-0 → 72h decision chain; learning review. 
• B-CAN: Plain-English reasons (≤140w block) & family notices. 
• B-S/T: Small-cell suppression & audit hash on reasons. 
• B-FN: First Nations protocols & wording; interpreter/AAC. 
• B-PUB / B-PUB-ADV: Publication notes; edge-case suppression. 
• B-CAL / B-RED: Panel calibration; red-team scenario for decision drift. 

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RPL (Recognition of Prior Learning)  -  Decision-quality pack 
Submit once per role change; keep de-identified. 
• Two recent decisions with R&W tables (0-4 weights) and Matrix IDs. 
• One plain-English reasons block (≤140 words) and the audit-log hash. 
• One Tier-0→72h example (timeline + review outcome). 
• Conflict-of-interest declaration and sample IPP independence note. 
• Referees: one internal judicial/registry, one external (e.g., OPA/DSC). 
• Outcome: credit mapped; Fast Bridge issued with Bench-OSCE/EPA bookings. 
RPL credit rules (quick): 
• Prior small-cell/suppression training without live examples → no credit until B-S/T 
is passed in-house. 
• Published decisions that omit weights or Matrix → RPL accepted for experience, 
but B-H/I-DQ remains mandatory. 
 
What good looks like / Red flags 
Good: short-form shows issues → weighted evidence → resolved contradictions → applied 
tests → decision & safeguards → review date → publication note; Two-Key independence is 
explicit; Tier-0 rolls into a clean 72-hour review; audit hash present. 
 
Red flags: single-actor consequential orders; titles cited as “weight”; reasons without a 
weights table; no Matrix; suppression missed; no review/expiry. 
 
Templates & artefacts  
• Two-Key Decision Record  -  Short Form (this section) 
• Will & Preferences Note 
• Tier-0/72-Hour Review sheet 
• DSC Calibration Memo (Two-Key) 
• Decision-Maker Fast Bridge plan (bench) 
• Bench-OSCE rubrics: Registrar/Member/Senior Member 
• RPL checklist (Decision-Quality) 
 
Summary companion. Two-Key is the guardrail; R&W short form is the language; the 
Matrix is how we resolve conflict; Tier-0 → 72h is the learning loop; suppression + audit 
hash keep the public record safe and checkable. The Fast Bridge + RPL ensure every 
registrar or member can deliver that - consistently. 
 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 338 
 
Appendix AO.3  -  RPL Evidence Checklist (Recognition of Prior Learning) 
 
Credits prior learning and competence fairly (work logs, supervision notes, incident 
reflections, family feedback). 
Owner: IDC Program (Workforce & Education) 
Interfaces: IDC Curriculum & OSCE/EPAs (Appx Q); Equivalency & Bridging (Appx 
AO/AO-1/AO-2/AO-6N); Reasons & Weighting / Matrix / IRC (Appx H-J); Communication 
Access (Appx N); Safety & Restrictive Practices + 72-Hour Review (Appx A-C); Handover 
& Medication Reconciliation (Appx D); Psychotropic Stewardship (Appx AB); 
Mealtime/IDDSI (Appx Z); First Nations Partnership (Appx O); Privacy/DPIA & 
Publication/Suppression (Appx R/S/AL); Audit Log Spec (Appx T); Owner Matrix & 
Escalation (Appx Y). 
Why this matters (and why it hasn’t worked) 
 
RPL has drifted into “CV review + certificates”. That misses what protects people: observed 
practice, access and least-restrictive thinking, warm handovers, document integrity, and 
privacy discipline. This checklist credits genuine competence and pinpoints bridges, using 
artefacts you can verify and re-create. 
Fast take (read this first) 
 
• One pack per person, one hour to review, verifiable in the audit log. 
• Evidence must show: access, reasoning (H/I/J), safety timing (A-C), handover quality (D), 
privacy discipline (R/S). 
• Map to a provisional IDC band, then issue a dated Bridging Plan with OSCE/EPA 
bookings. 
• No seniority waivers: at least one observed assessment (mini-OSCE/OSCE/EPA) before 
solo scope. 
Scope 
 
All applicants seeking IDC banding or bridge credit (frontline, coordination/navigator, 
clinical, management, regulator/DSC). Use the role-family tables in AO & AO-1/2/6N to 
select which modules are “must show”. 
 
Checklist (compile the pack; tick and attach IDs/links) 
 
A. Identity & provenance 
☐ AO-3 cover sheet (role sought; provisional band requested) 

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☐ Resume/CV (max 2 pages) + current registration (if clinical) 
☐ Audit references: feed_id(s) and anchor_ref (Appx T) for each attached artefact 
B. Supervised practice & logs (last 6-12 months) 
☐ Work-log excerpts (dates/hours, contexts) - ≥4 weeks representative 
☐ Supervision notes (frequency, topics, actions) - ≥4 entries with outcomes 
☐ Two external field observations (outside line) or equivalents (AO-7N for Navigators) 
☐ Attendance at 72-hour reviews (if triggered) - dates/roles 
C. Decision-quality artefacts (H/I/J) 
☐ One Reasons & Weighting table with probative weights (Appx H) (ID: ___) 
☐ One Contradiction Matrix page resolving at least one conflict (Appx I) (ID: ___) 
☐ One Independent-Reasoning Certificate (Appx J) signed by a second reviewer (ID: ___) 
D. Safety & least-restrictive practice (A-C / AB / Z) 
☐ Time-kept restraint/PRN example showing start/stop and review path (A-C/AB) 
☐ Mealtime/IDDSI artefact or acknowledgement (Z) if in scope 
☐ Evidence of booking/holding a 72-hour learning review where required (B-C) 
E. Access & culture (N/O) 
☐ Example of communication access (interpreter/Auslan/AAC) with consent note (N) 
☐ First Nations protocol/wording example or cultural broker involvement (O) (if relevant) 
F. Continuity & handover (D / AO-6N for Navigators) 
☐ Warm handover bundle (SBAR + named steward + “booked & kept” proof) (D) 
☐ Medication reconciliation status carried or confirmed (D) (if relevant) 
G. Integrity & privacy (R/S/T/AL) 
☐ E-receipt(s) with two-party attestation IDs (A10) and match-status (E/F) 
☐ Documentation-integrity sample (passes rubric or remediation shown) 
☐ Small-cell/suppression check note for any publication/tile use (S/AL) 
☐ Provenance hash/anchor for any exported bundle (T) 
H. Stakeholder corroboration 
☐ Family/representative feedback (≤140 words or survey result) 
☐ Cross-agency testimony (e.g., GP, school, ED) (optional but strong) 
I. Referees 
☐ One internal and one external referee, reachable, with roles and dates contacted 
Short video options (2-4 min; consented; de-identified where required) 
☐ Access conversation snippet (N) ☐ SBAR handover call snippet (D) 
(If video cannot be shared, attach structured observation notes with audit ID.) 
Scoring rubric (10 points; pass ≥7; any critical fail = remediation first) 

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1. Access present & recorded (N) - 0/1/2 
2. Least-restrictive reasoning evident (A-C) - 0/1/2 
3. Evidence weighting & conflict resolution (H/I) - 0/1/2 
4. Warm handover booked & kept (D / AO-6N) - 0/1/2 
5. Privacy/suppression discipline (R/S/AL) - 0/1/2 
Critical fails (auto-bridge before credit): 
• Missing access where needed • No time-keeping on restraint/PRN • Publication with 
small-cell breach • Fabricated/ unverifiable artefacts. 
Verification steps (reviewer use) 
 
• Check hashes/anchors (T) for any exported artefact; confirm IDs match. 
• Spot-call one referee; confirm roles and independence. 
• Run a file-vs-field check on one item (e.g., handover “kept”). 
• Record the review as an audit event (rpl_reviewed) with outcome and next steps. 
Outcome mapping → Bridging Plan (dated; owner; bookings) 
 
If Pass (≥7/10; no critical fails): 
• Provisional band = [IDC-1/2/3/4] per AO matrix + book required OSCE/EPA (≤30 days). 
If Borderline (6/10 or missing artefact): 
• Issue targeted bridges (B-modules) + mini-OSCE; re-present in ≤30 days. 
If Fail (<6/10 or critical fail): 
• Narrow scope; red-team micro-scenario if safety/independence failed; re-OSCE after 
remediation. 
Navigator-specific addendum (for AO-6N stream) 
 
Must include: 
• Two warm handovers with “booked & kept” outcome 
• One Reasons mini + Matrix reference 
• Privacy/suppression quick check note 
• Two external observations (outside line) 
Assessments to book: OSCE-HO; mini-OSCE-PUB; EPA-HO; EPA-CAN; EPA-PUB. 
What good looks like / Red flags 
 
Good: verifiable artefacts with hashes; short, neutral reasoning; access and privacy visible; 
handovers that actually happened; 72-hour reviews on triggers; referees answerable. 
Red flags: certificates without practice; “manager says competent”; no independence screen 
for consequential items; unsourced numbers; small-cell leaks; unverifiable videos. 
Where to get help / Artefacts & Templates 
 
• AO-3 cover sheet (fillable) • RPL evidence index (with hash fields) • Reviewer scorecard & 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 341 
 
decision note 
• Mini-OSCE booking sheet • Red-team micro-scenario prompt (safety/independence) • 
Privacy/suppression quick guide 
Summary companion. Decisions rely on the governing sections named in IDC 
Curriculum & OSCE/EPAs, Safety & Restrictive Practices, Communication Access, 72-
Hour Review, Handover/Medication, Psychotropic Stewardship, Mealtime/IDDSI, First 
Nations Partnership, DPIA/Publication, Audit Log, Owner Matrix & Escalation, and 
Candour/Tribunal/Ombudsman protocols. 
 
Appendix AP  -  Two-Key Guardianship (specific) 
 
Owner: Tribunal President (rules committee) · Operational owner: Principal Registrar 
Interfaces: Registry; Public Advocate/Guardian (OPA/OPG); Decision Support Consultant 
(DSC); treating team; service provider; person at centre and nominated supporters 
Related standards: IDC Workforce Standard; Independent Verification (DSC); Safety & 
Restrictive Practices; Truth-by-Design (e-receipts, roster-to-claim); Data, Dashboards & 
Privacy. 
 
Why this matters (failure modes addressed) 
 
• Single-actor decisions under time pressure; weak documentation of how objections 
were weighed. 
• Emergency practices become habitual; ‘consultation’ unlogged; appeal records partial 
or late. 
• Capture and conflicts where the same pair sign repeatedly without rotation or 
independence checks. 
• Inaccessible service and reasoning for the person and their supporters. 
 
Fast Take (read this first) 
 
• No single-person major decisions. 
• Emergency single-key permitted only for imminent risk, with a 72-hour review and 
fade plan. 
• Appeal-ready record: written reasons + R&W + (if used) Contradiction Matrix + IRC 
+ exhibits schedule must be served before the appeal clock runs. 
• Publication cadence: de-identified reasons + tiles each quarter. 
 
Scope 
 
Applies to all guardianship/administration matters and any tribunal direction authorising 
significant medical, living, safety, legal or financial decisions. 
 
Definitions 
 

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• Two-Key: two independent keys recorded for any in-scope decision (authorised 
decision-maker + paired co-decision key). 
• MPG (Multi-Person Guardianship) Quorum: a quorum (e.g., 3) for complex/contested 
liberty-reducing decisions, including at least one external member. 
• Emergency (Tier-0): imminent risk requiring immediate action; followed by a 72-hour 
learning review and a Two-Key decision. 
• Will-and-Preferences Record: the person’s stated will and preferences (with supported 
decision-making), recorded in accessible language. 
• R&W (Reasons & Weighings) Table: structured table linking issues → evidence → 
probative weight → findings. 
• Contradiction Matrix: file-vs-field reconciliation where evidence conflicts. 
• IRC (Independent Reasoning Certificate): a signed checklist confirming least-
restrictive analysis, options considered, rights impacts, and reasons quality. 
• IPP (Independent Pairing Pool): registry-maintained roster used to source an 
independent second key within service levels. 
• Calibration Memo (Two-Key): DSC short memo rating co-sign independence, R&W 
quality, and will-and-preferences fidelity. 
 
Minimum Standard (must be true to proceed) 
 
• Two independent keys are documented: (a) authorised decision-maker; and (b) paired 
co-decision key (OPA/OPG delegate, DSC-paired professional, or court-recognised 
supporter). 
• Contradictions between file and field are logged in a Contradiction Matrix where 
present. 
• An R&W table accompanies the written reasons. 
• An IRC is completed, confirming alternatives considered, least-restrictive test, and 
rights impacts. 
• Service is effected in accessible form to the person and their representative. 
 
Model Text  -  Practice Note (adopt or adapt) 
 
• Two-Key rule. No order may authorise a major decision unless two independent 
approvals are recorded and served. 
• Emergency exception. A single key may authorise time-critical actions only to 
prevent serious and imminent harm. The order must: (i) specify the risk; (ii) limit 
scope to the minimum necessary; (iii) schedule a Two-Key review within 72 hours; 
(iv) require a fade plan. 
• Appeal-ready record. Time to seek review/appeal does not begin to run until service 
of: (a) written reasons; (b) R&W table; (c) Contradiction Matrix (if applicable); (d) 
IRC; (e) exhibits schedule. 
• Publication. The registry publishes de-identified reasons and R&W tables quarterly 
with open-justice tiles (time-to-reasons; % with R&W; % with IRC). 

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• Equity. Where the person is First Nations, CALD or uses Auslan/AAC, supports must 
be arranged; service occurs in accessible form. 
 
Independence & Conflict Rules 
 
• Co-signers must be independent: no direct financial conflicts; not both employed by 
the same provider team making/benefiting from the decision. 
• Rotation and pairing limits: same-pair cap per quarter; exceeding cap triggers DSC 
sampling (≥20% next quarter). 
• Conflict declaration required for all keys; cooling-off rules apply where a prior 
relationship exists. 
• Where a second key is unavailable/recused, the IPP must pair an independent key 
within 72 hours (tele-co-sign acceptable with identity check and recorded reason). 
 
Quorum Models 
 
• Standard: Two-Key (two independent keys) for most decisions. 
• MPG: quorum of 3 for complex/contested liberty-reducing decisions (must include at 
least one external member). 
• Emergency Quorum: 2-of-5 with TTL 72 hours for time-critical safety events; 
mandatory post-hoc DSC review; auto-reversal if review fails. 
 
Roles & Responsibilities 
 
• Tribunal/Commissioner: decision-maker of record; issues determinations; maintains 
practice notes; sets rotation thresholds. 
• Principal Registrar: maintains IPP; ensures registry checks; schedules reviews; 
oversees publication. 
• OPA/OPG/Guardians: provide a key or quorum seat; maintain conflicts/rotation 
registers; ensure cultural pairing where feasible. 
• DSC: independent verification where risk/contest is present; provides Calibration 
Memo; reconciles file-vs-field; supports lawful, reviewable decisions. 
• IDC & treating team: lead SDM; maintain timekeeping; conduct 72-hour learning 
reviews; prepare documentation packs (including Will-and-Preferences record). 
• Providers/COORD licence holders: log R&W and Two-Key details where they 
influence decisions; maintain independence from provision. 
 
Process  -  End-to-End (Registry Checklist Embedded) 
 
• Intake & triage: identify if decision falls within scope; check for emergency flag; 
assign case number. 
• Pairing: verify two independent keys; if none available, initiate IPP pairing within 72 
hours; record conflicts/independence screen. 

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• Evidence pack: assemble plans, notes, incidents, medication, rosters/claims, e-
receipts, previous orders; confirm cultural/communication supports 
(interpreters/AAC). 
• Field check (if DSC engaged): schedule targeted observations; gather neutral 
artefacts; complete Contradiction Matrix where discrepancies arise. 
• Hearing/decision: record Will-and-Preferences; apply least-
restrictive/proportionality/necessity tests; log votes/approvals. 
• Record & serve: written reasons + R&W + (if used) Contradiction Matrix + IRC + 
exhibits schedule; serve in accessible form; log service date. 
• Emergency handling: if single-key used, specify risk/scope; schedule Two-Key 
review within 72 hours; require fade plan; mark for DSC post-hoc review. 
• Publication: de-identified reasons and tiles queued for quarterly batch; apply 
suppression (n < 5) and redaction per DPIA. 
• Follow-up: actions and due dates entered on dashboards; monitor rotation health and 
emergency exception use. 
 
Artefacts  -  Templates & Minimum Content 
 
Two-Key Decision Record (short form) 
 
• Matter ID; date; decision class; keys (names/roles/independence declarations). 
• Will-and-Preferences summary (plain language/Easy Read). 
• Decision outcome; actions; review date; publication flag. 
 
Reasons & Weighings (R&W) Table 
 
• Issues/questions; evidence source/date; relevance; probative weight (scaled); 
analysis; finding; reason. 
• Alternatives considered; least-restrictive test; rights impacts; why chosen option 
best fits will-and-preferences. 
 
Contradiction Matrix (if contradictions present) 
 
• Item/claim; file says; field shows; other sources (e-receipts/rosters/clinician 
notes); resolution (accept/discard/seek more); residual uncertainty. 
 
Independent Reasoning Certificate (IRC) 
 
• Scope, data sources, observation dates/contexts, communication supports used; 
conflicts declared. 
• Summary of variance (file vs field); rights tests applied; signature (decision-
maker/reviewer). 
 
Calibration Memo (Two-Key)  -  DSC 
 

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• Co-sign independence rating; R&W quality; will-and-preferences fidelity; 
rotation/bias notes; recommended remediation/calibration actions. 
 
Independence & Rotation  -  Detailed Rules 
 
• Independence screen must be completed for both keys: financial interests, 
employment ties, familial/close relationships, prior involvement in the case. 
• Same-pair cap: policy-set threshold (e.g., ≤25-33% of decisions per quarter). 
Exceeding cap requires written justification and triggers DSC sampling in the next 
quarter. 
• Conflict handling: if conflict unavoidable in thin markets, record mitigations (external 
observer, DSC sampling, time-bound pairing) and reasons for proceeding. 
• Cooling-off: minimum period (e.g., 24 months) where a key has been employed by or 
contracted to the provider involved. 
 
Equity & Accessibility 
 
• First Nations cultural safety requirements; access to interpreters (including Auslan) 
and AAC; culturally appropriate pairing for the second key where feasible. 
• Service and reasons provided in accessible forms (Easy Read, plain English, formats 
compatible with assistive tech). 
• Track equity tiles: interpreter/AAC utilisation; cultural pairing rate; outcomes by 
cohort (de-identified). 
 
Data, Dashboards & Privacy 
 
• Tiles (minimum): time_to_reasons_median_days; pct_decisions_with_rw; 
pct_decisions_with_irc; pct_two_key_coverage; 
pct_emergency_exceptions_within_rules; pct_reviews_completed_72h; 
rotation_health. 
• Privacy-by-design: DPIA for each artefact; minimum-necessary data; role-based 
visibility; suppression n < 5; redaction rules for public releases. 
• Family-view dashboards: status and due dates sans sensitive content; public tiles de-
identified and aggregated. 
 
Registry Fields  -  Minimum Dataset 
 
• Case metadata: matter ID; dates (lodgement, decision, service); decision class; 
emergency flag. 
• Keys: names/roles; independence checks; conflicts; rotation counter; IPP pairing 
source if used. 
• Artefacts: reasons served Y/N; R&W attached Y/N; Contradiction Matrix used Y/N; 
IRC Y/N; Calibration Memo Y/N. 
• Equity: interpreter/AAC used; cultural pairing; accessible formats provided. 

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• Outcomes: actions and due dates; review date; publication date; appeals filed Y/N. 
 
Compliance, Audit & Sanctions 
 
• Audit cadence: quarterly sampling (≥10% or risk-weighted) for artefact completeness 
and independence compliance. 
• Sanctions ladder: improvement plan → licence/contract conditions → administrative 
fines → de-preference/debarment → publication on registry. 
• Exception governance: emergency use beyond threshold triggers targeted audit and 
calibration. 
 
Rural & Thin-Market Parity 
 
• IPP with 72-hour SLA to source independent keys; tele-co-sign permitted with 
identity check; satellite session scheduling. 
• No dilution of standards: Two-Key/MPG, artefacts, and publication rules remain 
unchanged in rural or thin markets. 
• Weather-miss protocol: reschedule within 10 business days; document any adjusted 
minima. 
 
Implementation (Switch-On Order) 
 
• 0-3 months: issue Practice Note; stand up IPP; publish templates and DPIA; configure 
registry fields and dashboard tiles; staff training. 
• 3-6 months: pilot (1 metro + 1 rural); target ≥90% Two-Key coverage; median co-
sign ≤72h moving to ≤48h; first publication batch. 
• 6-12 months: extend to priority cohorts; publish calibration & rotation report; embed 
emergency-quorum post-hoc checks. 
• 12-24 months: full regional parity; independent evaluation; integrate with 
procurement/accreditation conditions. 
 
 
Version & Review 
 
v1.0. Rules Committee reviews 6-monthly with OPA/OPG and registry; updates recorded in 
release notes. 
 
 
 
 
 
 

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Appendix AQ  -  OPA/OPG Investigations Code Addendum: Two-Key 
Guardianship 
 
Owner: Public Advocate/Guardian (state) · Operational owner: Investigations Manager 
Interfaces: Interfaces: Tribunal/Registry; Decision Support Consultant (DSC); police (where 
harm/risk); providers; families; First Nations partners. 
Related standards: Appendix AP  -  Two-Key; Independent Verification (DSC); Safety & 
Restrictive Practices; Truth-by-Design; Data, Dashboards & Privacy. 
 
Why this matters (failure modes addressed) 
 
• Investigations triggered after unilateral decisions with missing consent trails and 
unverified ‘emergencies’. 
• Families and supporters lose trust; investigators reconstruct basic facts instead of 
testing reasoning quality. 
• Lack of rotation/independence checks for second keys; emergency exceptions over-
used without timely review. 
 
Fast Take (read this first) 
 
• Verify Two-Key coverage first. 
• If emergency single-key used: confirm imminent-risk threshold and the 72-hour 
review outcome and fade plan. 
• Always extract the appeal-ready record and include outcomes in de-identified 
quarterly notes. 
 
Scope 
 
Applies to all OPA/OPG investigations where major decisions, restrictive practices, or 
placement changes are alleged or contemplated. Includes preliminary enquiries and full 
investigations. 
 
Definitions 
 
• Two-Key: two independent keys recorded for any in-scope decision (authorised 
decision-maker + paired co-decision key). 
• Emergency exception (Tier-0): immediate, serious risk requiring single-key action, 
followed by a 72-hour review and fade plan. 
• R&W (Reasons & Weighings) table: structured issues→evidence→weight→finding 
matrix accompanying written reasons. 
• Contradiction Matrix: file-vs-field reconciliation tool where evidence conflicts. 
• IRC (Independent Reasoning Certificate): checklist confirming options considered, 
least-restrictive test, rights impacts. 

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• IPP (Independent Pairing Pool): roster used to source an independent second key 
within service levels. 
• Calibration Memo (Two-Key): DSC memo rating co-sign independence, R&W 
quality, and will-and-preferences fidelity. 
 
Minimum Standard (investigation entry gates) 
 
• Two-Key verification: collect identities, roles, independence checks, timestamps for 
both keys; rotation check against registry thresholds. 
• Emergency audit: if single-key used, verify criteria: imminent risk; minimum scope; 
Two-Key review scheduled and completed within 72 hours; fade plan in place; DSC 
post-hoc review if required. 
• Evidence balance: complete/obtain R&W table; log contradictions via Contradiction 
Matrix if discrepancies present. 
• Safeguards: confirm service in accessible form; interpreter/AAC usage; cultural safety 
steps; will-and-preferences record obtained. 
 
Model Code (use/adapt for internal manuals) 
 
• At intake, determine whether Two-Key applied or emergency exception invoked; 
record basis and artefacts present/absent. 
• Where Two-Key absent without emergency criteria: issue Remedy Direction - (i) 
reinstate decision to neutral (no effect), (ii) convene Two-Key case conference within 
5 business days via IPP if needed, (iii) notify the tribunal where a current order is 
implicated. 
• Findings report must include: (a) Two-Key compliance status; (b) rights impact 
analysis; (c) remedies ordered; (d) referral where wilful breach suspected. 
• Close-out requires accessible service of findings to the person/representative and 
logging for quarterly publication. 
 
Process (10 Steps  -  with artefacts & service checks) 
 
• Intake & triage: classify risk; conflict screen for investigators; secure records; create 
investigation plan. 
• Duty of care check: ensure immediate safety; if emergency ongoing, issue interim 
advice on least-restrictive action and set 72-hour review. 
• Two-Key verification: confirm two independent keys, independence screens, 
timestamps, rotation status; if missing, initiate IPP pairing. 
• Emergency audit (if any): verify imminent risk, minimum scope, 72-hour review 
scheduling/completion, fade plan; set DSC post-hoc review where indicated. 
• Interviews (person first): obtain will-and-preferences with SDM; arrange 
interpreters/AAC; document consent and supports used. 
• Records request: written reasons; R&W; Contradiction Matrix (if used); IRC; exhibits 
schedule; provider logs (timekeeping; e-receipts; rosters-to-claims). 

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• Contradiction Matrix: reconcile file vs field; document residual uncertainty; capture 
neutral artefacts (receipts, logs). 
• Findings + Remedy Direction: determine compliance; order remedies (neutralise 
decision; convene Two-Key; training/calibration; referral). 
• Service in accessible form: Easy Read/plain English; log service date and method; 
provide rights-to-review information. 
• Publication: add de-identified outcome to quarterly notes; update dashboard tiles and 
registry fields. 
 
Artefacts & Templates (minimum content) 
 
Investigation Plan 
 
• Scope/issue; risk; decision class; timeline; records to obtain; interview plan; 
cultural/communication supports. 
• Conflicts for investigators; independence checks; escalation plan if harm emerges. 
 
Two-Key Verification Sheet 
 
• Keys (names/roles); independence declarations; rotation status; timestamps; IPP 
pairing reference if used. 
 
Emergency Exception Audit Sheet 
 
• Imminent risk description; actions taken; scope minimisation; 72-hour review 
scheduling/completion; fade plan detail; DSC post-hoc review tick. 
 
R&W Table + Contradiction Matrix 
 
• R&W: issues; evidence; weight; analysis; finding; reason; alternatives; least-
restrictive test; rights impacts. 
• Contradiction Matrix: item; file says; field shows; other sources; resolution; residual 
uncertainty. 
 
Findings Report & Remedy Direction 
 
• Compliance status; rights impact; ordered remedies and timeframes; referrals; 
publication flag; appeal/complaint guidance. 
 
Interfaces with DSC & Tribunal 
 
• Trigger DSC where facts contested, rotation concerns, or emergency exception 
disputed; request Calibration Memo and (if needed) limited field checks. 
• Notify tribunal where existing orders implicated or where Remedy Direction requires 
case conference/Two-Key compliance. 

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• Share artefact pack (R&W, Contradiction Matrix, IRC) to make orders appeal-ready. 
 
Registry Fields & Dashboards 
 
• Case metadata: ID; intake date; decision class; emergency flag; sector (home, health, 
justice). 
• Two-Key: keys/roles; independence screens; rotation counters; IPP reference. 
• Artefacts: reasons Y/N; R&W Y/N; Contradiction Matrix Y/N; IRC Y/N; DSC memo 
Y/N. 
• Equity: interpreter/AAC used; cultural safety steps; accessible service provided. 
• Outcomes: remedies; due dates; completion status; publication date; referral made 
Y/N. 
 
Tiles (publish de-identified quarterly) 
 
pct_investigations_two_key_compliant; pct_emergency_exceptions_validated; 
median_time_to_remedy; referrals_made_count; rotation_health. 
 
Equity & Accessibility 
 
• First Nations partnership; cultural pairing where feasible; interpreters (including 
Auslan) and AAC arranged before interviews. 
• Accessible service (Easy Read/plain English; assistive-tech compatible formats). 
• Track equity tiles and include notes in quarterly summaries (de-identified). 
 
Rural & Thin-Market Parity 
 
• IPP rapid pairing SLA; tele-interviews/co-sign with identity checks; satellite sessions 
where needed. 
• No dilution of standards; emergency quotas audited; weather-miss protocol 
(reschedule ≤10 business days). 
 
Governance, Sanctions & Referrals 
 
• Sanctions ladder for wilful or repeated non-compliance: improvement plan → 
conditions → administrative fines → de-preference/debarment → publication. 
• Referral triggers: suspected fraud; abuse/neglect; breach of orders; obstruction; 
document fabrication. 
• Quarterly calibration workshop with DSC/Tribunal to review patterns and update 
guidance. 
 
Implementation (Switch-On Order) 
 
• 0–3 months: publish addendum; train investigators; stand up IPP link; add registry 
fields; configure dashboards; release templates & DPIA. 

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• 3–6 months: pilot; publish first de-identified notes; baseline tiles; embed DSC 
triggers; rotation health reporting. 
• 6–12 months: expand; quarterly calibration; refine Remedy Direction templates; 
external audit sample. 
• 12–24 months: full integration with tribunal practice notes; independent evaluation 
and public report. 
 
Measures (Performance Management) 
 
pct_investigations_two_key_compliant; pct_emergency_exceptions_validated; 
median_time_to_remedy; referrals_made_count; rotation_health; 
equity_supports_provided_pct. 
 
Version & Review 
 
v1.0. Review each 6 months with Tribunal and Analytics; update release notes with any 
changes. 
 
 
 
Appendix AR  -  Procurement Direction & Independent Pairing Pool (IPP) 
Service-Level Agreement 
 
Owner: Central Procurement (Disability/Justice portfolio) · Operational owner: IPP Panel 
Manager 
Interfaces: Tribunal Registry; OPA/OPG; DSC program; providers; First Nations partners; 
finance/audit 
 
Why this matters (and why it hasn’t worked) 
 
Second keys are improvised or conflicted. Panels exist but are slow, metro-centred, and 
opaque on conflicts. 
 
Fast take (read this first) 
 
• Maintain a rotating, conflict-screened pool for the second key. 
• Response in 2 hours urgent / 2 business days standard. 
• Pair by skills + independence; log every pairing and outcome. 
 
Scope 
 
Standing offer arrangement to supply qualified co-decision participants (clinician, advocate, 
legal/ethics, peer) to act as the second key for major decisions. 
 
Minimum standard 
 
• Panel composition: at least 4 categories  -  senior clinician, disability advocate, 
legal/ethics, peer/family; with rural/remote representation. 

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• Independence & conflicts: written declaration each assignment; exclusions include 
current employer/provider, family ties, financial interest. 
• Capability: verified credentials; observed practice or equivalent; cultural 
competence; Auslan/AAC literacy for relevant streams. 
• Privacy & security: ISO-style handling; secure comms; records retained per 
retention schedule. 
 
Pairing algorithm (order of preference) 
 
1 Skills match to decision domain → 2 Jurisdiction & cultural fit → 3 Independence score → 
4 Geography/tele-readiness → 5 Rotation / workload balance. 
 
Service levels 
 
• Urgent (risk of serious harm): acceptance within 2 hours; joint decision within 24 
hours; 72-hour review scheduled. 
• Standard: acceptance in 2 business days; joint decision within 10 business days. 
• Failure to meet SLA: escalate to Panel Manager; alternate pairing within 4 hours 
(urgent) / 1 day (standard). 
 
Outputs (per engagement) 
 
• Co-decision note with signatures/time-stamps. 
• R&W table entries relevant to the decision. 
• IRC co-sign or dissent note. 
• Conflicts declaration and independence checklist. 
 
Pricing & funding (indicative) 
 
• Call-out fee (urgent) capped; hourly rates by category; rural loadings; travel at 
government rates. 
• Funding source: tribunal/OPA cost-centre with recoveries via program budgets where 
applicable. 
 
Quality & audit 
 
• Quarterly sample review; client feedback; breach ladder (warn → suspend → 
remove). 
• Equity metrics: rural fulfilment rate; First Nations and CALD pair availability. 
 
Measures (tiles) 
 
ipp_response_time_median; pct_pairings_meet_sla; pct_pairings_conflict_free; 
rural_pairing_rate; client_feedback_score_median. 
 
Version & review 
 
v1.0; annual market refresh; six-monthly KPI review. 
 

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Appendix AS  -  Dashboard Tile Specifications: Two-Key Guardianship 
Owner: Lead Agency Analytics Unit · Operational owner: Registry/OPA Data Stewards 
Interfaces: Tribunal CMS; OPA/OPG case system; IPP logs; provider incident systems; 
public dashboard 
Why this matters (and why it hasn’t worked) 
 
Narrative reports hid exceptions; timing drifted; publication was irregular. Standard tiles 
make risk and progress visible, quarterly. 
 
Fast take (read this first) 
• Four public tiles; two internal QA tiles. 
• Quarterly, de-identified; suppression <5. 
• Every payload includes: metric, value, period (YYYY-Qn), source, last_updated (ISO 8601), 
optional notes. 
• Source files (machine-readable): /dashboards/reasons_tiles_example.json, 
/dashboards/reasons_tiles_dictionary.md, /schemas/dashboard_template.json. 
Tile dictionary (table view) 
Metric What it measures 
(definition) 
Numerator / 
Denominator Period Source 
systems Public? 
pct_two_key_coverage Share of major decisions 
with two independent keys 
Num: decisions with 
two keys · Den: all 
major decisions 
finalised 
YYYY-
Qn 
Tribunal 
registry; IPP 
pairing log 
Yes 
emergency_exceptions_rate Share using Tier-0 single-
key pathway 
Num: Tier-0 
decisions · Den: all 
major decisions 
finalised 
YYYY-
Qn 
Tribunal 
registry Yes 
reviews_completed_72h % of Tier-0 decisions 
reviewed ≤72h 
Num: Tier-0 with 
review ≤72h · Den: 
all Tier-0 decisions 
YYYY-
Qn 
Registry 
scheduler / 
case mgmt 
Yes 
time_to_second_key_median_hours 
Median hours from pairing 
request → confirmed second 
key 
Median( confirm_ts − 
request_ts ) 
YYYY-
Qn IPP pairing log Yes 
pct_pairings_conflict_free % pairings passing 
independence/conflict checks 
Num: conflict-free 
pairings · Den: all 
pairings 
YYYY-
Qn 
IPP conflict 
declarations Internal 
contradiction_resolved_rate 
% Contradiction Matrix 
entries closed ≤14 days 
(Two-Key matters) 
Num: entries closed 
≤14d · Den: entries 
opened in period 
YYYY-
Qn 
DSC case 
register; 
Matrix log 
Internal 
 
 
 
Inclusion / exclusion (edge cases, minimal) 
• Major decisions: liberty, health, home, money, relationships (exclude routine daily 
care). 
• Count once at finalisation; if revoked/re-made same quarter, keep the latest only. 
• Tier-0 valid only where imminent serious harm is documented; repeat flags on one 
episode count once. 

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• Include tele-pairings. Timestamps use Australia/Melbourne; keep offset in 
last_updated. 
Computation rules (normative, one-liners) 
• pct_two_key_coverage = keys✓ / decisions_finalised × 100 
• emergency_exceptions_rate = tier0 / decisions_finalised × 100 
• reviews_completed_72h = tier0_reviewed≤72h / tier0 × 100 
• time_to_second_key_median_hours = median( confirm_ts − request_ts ) hours 
Payload requirements (all tiles) 
metric (string) · value (number) · period (YYYY-Qn) · source (string list) · last_updated (ISO 8601 
+ offset) · notes (optional). 
Suppress or aggregate where any underlying cell <5. 
Example payload (JSON) 
[ 
  { 
    "metric": "pct_two_key_coverage", 
    "value": 86.4, 
    "period": "2025-Q3", 
    "source": "tribunal_registry; ipp_log", 
    "last_updated": "2025-10-05T10:12:00+10:00", 
    "notes": "Includes remote tele-pairings" 
  }, 
  { 
    "metric": "emergency_exceptions_rate", 
    "value": 7.2, 
    "period": "2025-Q3", 
    "source": "tribunal_registry", 
    "last_updated": "2025-10-05T10:12:00+10:00", 
    "notes": "Imminent risk only; see PN s.2" 
  } 
] 
 
 
 
Data lineage & QA (publication gates) 
• Freeze window: lock 10 calendar days after quarter end. 
• Must pass: 
o ≥99% decisions have service date & type, 
o 100% Tier-0 have booked review timestamps, 
o No negative or >365-day durations; no future-dated events, 
o Registry finalisations reconcile with denominators used. 
Publication & suppression 
• Public: quarterly PDF/HTML + JSON; internal QA tiles remain internal. 
• Dashboard footer: “Last checked: DD-MM-YYYY · Method v1.0 · Suppression <5”. 
Version & review 
v1.0; review quarterly with Registry/OPA. 

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Appendix AT  -  Talking Points & Q&A: Two-Key Guardianship 
Owner: Lead Communications (with Tribunal/OPA) · Operational owner: Media & 
Briefings Team 
Interfaces: Ministers’ offices; tribunal leadership; OPA/OPG; providers; unions; family peak 
bodies 
Why this matters (and why it hasn’t worked) 
Unilateral practice persisted because it felt faster and cheaper. It wasn’t. It created risk, 
appeals, and distrust. 
Fast take (read this first) 
• Two-Key is not bureaucracy; it’s a safety mechanism. 
• Emergencies still move fast; we review within 72 hours. 
• Families and workers get clearer reasons and easier appeals. 
Plain-language talking points (30-60 sec) 
• No one decides alone on major life decisions. A second, independent key checks that 
options are least-restrictive and rights-respecting. 
• When it’s urgent, one key can act, but only to keep someone safe. We then review 
within 72 hours and plan to step down. 
• We publish our reasons (in plain English) and the simple table that shows how we 
weighed the evidence. Appeals run from when the full record is served. 
• Frontline workers are backed by simple templates and a neutral pairing pool to 
keep decisions on time. 
• Dashboards track it all: reasons published, time-to-reasons, Two-Key coverage, and 
emergency use. 
Q&A (objections you’ll hear, answers you can stand behind) 
• Q: Won’t this slow everything down? 
A: No. Urgent cases still move immediately. For all others, the IPP supplies the 
second key within two business days; urgent in two hours. The gain is fewer reversals 
and safer outcomes. 
• Q: What if the existing sole guardian is doing a great job? 
A: Keep them. Two-Key doesn’t replace good guardianship; it adds a second set of 
eyes on major decisions, like a surgical “time-out”. It protects good practice. 
• Q: Who is the second key? 
A: An independent, conflict-screened professional from a standing pool - clinician, 
advocate, legal/ethics, or trained peer - matched to the decision. 
• Q: Isn’t this expensive? 
A: It’s cheaper than failed placements, preventable hospitalisations, and litigation. 
Panels cap rates and prioritise tele-pairings for rural/remote. 
• Q: Won’t people collude? 
A: Independence checks, rotation rules, and random audits reduce that risk. 
Contradictions between file and field are logged and resolved. 

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• Q: What about cultural safety and language access? 
A: Pairings must fit the person’s culture and language. Auslan/AAC and First Nations 
partners are built into the pool. 
• Q: How do families appeal? 
A: They receive the full appeal-ready record - reasons, the weighing table, exhibits - 
so the clock starts from service, not from rumour. 
Call to action (for each audience) 
• Ministers: announce Two-Key with the practice note and the open-justice tiles; 
publish first quarterly results in 90 days. 
• Tribunal leaders: adopt the PN; train registry; switch on templates. 
• OPA/OPG: apply the investigations addendum; report emergency audits quarterly. 
• Providers: prepare for independent pairings; use the e-receipt and R&W tools. 
• Families: ask for the appeal-ready record and an Easy-Read version. 
Version & review 
v1.0; update after first quarter of publication. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

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Appendix AU  -  Bibliography 
(Alphabetised list of sources - books, articles, standards and websites - relevant to this white 
paper. Some entries are foundational reference works that may not be explicitly cited in-text.)  
Aged Care Quality and Safety Commission. (n.d.). Minimising restrictive practices. 
https://www.agedcarequality.gov.au/safe-care/behaviour-support/minimising-restrictive-practices  
AHPRA & National Boards. (2020). Aboriginal and Torres Strait Islander Health and Cultural Safety 
Strategy 2020-2025. https://www.ahpra.gov.au/About-Ahpra/Aboriginal-and-Torres-Strait-Islander-
Health-Strategy.aspx  
Angrist, J. D., & Pischke, J.-S. (2009). Mostly harmless econometrics: An empiricist’s companion. 
Princeton University Press. https://press.princeton.edu/books/hardcover/9780691120355/mostly-
harmless-econometrics  
Australian Bureau of Statistics. (n.d.). The Five Safes framework. 
https://www.abs.gov.au/statistics/research/technical-papers/five-safes  
Australian Commission on Safety and Quality in Health Care. (n.d.). Medication Safety Standard 
(NSQHS). https://www.safetyandquality.gov.au/standards/nsqhs-standards/medication-safety-standard  
Australian Signals Directorate. (n.d.). Event logging and monitoring guidance. 
https://www.cyber.gov.au/resources-business-and-government/maintain-security/event-logging-and-
monitoring  
Beukelman, D. R., & Mirenda, P. (2013). Augmentative and alternative communication: Supporting 
children & adults with complex communication needs (4th ed.). Paul H. Brookes.  
Bernal, J. L., Cummins, S., & Gasparrini, A. (2017). Interrupted time series regression for the 
evaluation of public health interventions. International Journal of Epidemiology, 46(1), 348-355. 
https://doi.org/10.1093/ije/dyw098  
Carr, E. G., Dunlap, G., Horner, R. H., Koegel, R. L., Turnbull, A. P., Sailor, W., … Fox, L. (2002). 
Positive behavior support: Evolution of an applied science. Journal of Positive Behavior 
Interventions, 4(1), 4-16.  
Committee on the Rights of Persons with Disabilities (CRPD Committee). (2014). General Comment 
No. 1: Article 12 - Equal recognition before the law. United Nations.  
Disability Royal Commission. (2023). Final Report (12 vols). 
https://disability.royalcommission.gov.au/publications/final-report  
Gwet, K. L. (2008). Computing inter-rater reliability and its variance in the presence of high 
agreement. Statistical Methods for Inter-Rater Reliability. https://doi.org/10.1002/asmb.779  
Harden, R. M., & Gleeson, F. A. (1975). Assessment of clinical competence using an objective 
structured clinical examination (OSCE). British Medical Journal, 1(5955), 447-451. 
https://www.bmj.com/content/1/5955/447  
IDDSI (International Dysphagia Diet Standardisation Initiative). (n.d.). IDDSI Framework. 
https://iddsi.org/Framework/  

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Medical Education - see ten Cate (2005).  
Mitchell, M., Wu, S., Zaldivar, A., Barnes, P., Vasserman, L., Hutchinson, B., … Gebru, T. (2019). 
Model cards for model reporting. arXiv preprint. https://arxiv.org/abs/1810.03993  
National Aboriginal and Torres Strait Islander Health Plan 2021-2031. (2021). Australian 
Government, Department of Health and Aged Care. 
https://www.health.gov.au/resources/collections/national-aboriginal-and-torres-strait-islander-health-
plan-2021-2031  
NDIS Quality and Safeguards Commission. (n.d.). Regulated restrictive practices. 
https://www.ndiscommission.gov.au/resources/restrictive-practices  
NHS England. (n.d.). E-rostering good practice. https://www.england.nhs.uk/ourwork/nhs-
people/workforce-and-training/e-rostering/  
NIST. (2020). Security and Privacy Controls for Information Systems and Organizations (SP 800-53 
Rev. 5). National Institute of Standards and Technology. https://doi.org/10.6028/NIST.SP.800-53r5  
NIST. (2006/2012). Guide to Computer Security Log Management (SP 800-92). National Institute of 
Standards and Technology.  
Office of the Australian Information Commissioner (OAIC). (n.d.). Guide to undertaking privacy 
impact assessments (PIAs). https://www.oaic.gov.au/privacy/privacy-guidance-for-organisations-and-
government-agencies/guide-to-undertaking-privacy-impact-assessments  
Office of the Australian Information Commissioner (OAIC). (2024). De-identification and the 
Privacy Act. https://www.oaic.gov.au/privacy/privacy-guidance-for-organisations-and-government-
agencies/de-identification-and-the-privacy-act  
Schalock, R. L., & Verdugo, M. A. (2012). A leadership guide for today’s disabilities organizations: 
Overcoming challenges and making change happen. Paul H. Brookes.  
Speech Pathology Australia. (n.d.). IDDSI resources & endorsement. 
https://www.speechpathologyaustralia.org.au/SPAweb/Resources_for_the_Public/Eating__Drinking_
and_Swallowing/IDDSI.aspx  
Standards Australia. (2020). AS ISO 21998:2020  -  Healthcare interpreting - Requirements and 
recommendations. Standards Australia/ISO.  
ten Cate, O. (2005). Entrustability of professional activities and competency-based training. Academic 
Medicine, 80(10), 452-457. https://doi.org/10.1097/00001888-200505000-00023  
United Nations. (2006). Convention on the Rights of Persons with Disabilities (CRPD). 
https://www.un.org/development/desa/disabilities/convention-on-the-rights-of-persons-with-
disabilities.html  
World Health Organization. (2017). Medication Without Harm: WHO Global Patient Safety 
Challenge. WHO.  
World Health Organization. (2019). Medication safety in transitions of care. WHO. 
https://www.who.int/publications/i/item/WHO-UHC-SDS-2019.10  

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Glossary & Acronyms 
(Plain-English definitions for ministers, practitioners and the public) 
 
People, roles and programs 
• ABI  -  Acquired brain injury. Brain injury after birth (e.g., traumatic injury, 
hypoxic/anoxic insult, stroke-related cognitive impacts, infection, tumour). Effects 
may include changes in cognition, communication, behaviour, mood and function. 
• AHPRA  -  Australian Health Practitioner Regulation Agency. Regulator for 
registered health professions. 
• ID  -  Intellectual disability. Lifelong condition involving significant limitations in 
(a) intellectual functioning and (b) adaptive behaviour, with onset before 18. Person-
first language; not a mental illness; support needs vary widely. 
• TBI  -  Traumatic brain injury. A subset of ABI from external force (e.g., blows to 
head, falls, crashes). 
• IDC  -  Integrated Disability Clinician. Licensed, nurse-grade frontline practitioner 
for cognitive-disability support, with supervised practise, observed exams (OSCEs) 
and periodic revalidation. 
• IDC-Prep. Two-year mapped education program (AQF 5 Diploma or assessed 
equivalent) that qualifies a person to enter IDC licensing. 
• IDC-Paeds. IDC paediatric module set for early-years and school-age practice 
(communication/AAC, feeding and mealtime safety, sensory/behaviour coaching, 
school interface). 
• DSC  -  Decision Support Consultant. Neutral, tribunal/OPA/Ombudsman-facing 
professional appointed in contested/complex matters to run a short file-vs-field 
calibration and lodge a Calibration Memo attached to Reasons & Weighting. 
Verifies observable signals (e.g., OSCE currency, two-party e-receipts, CPI 
recompute, attention/digital exposure), resolves contradictions in a matrix, and 
recommends corrective actions. DSCs do not sanction. 
• IPP (Independent Pairing Pool) 
• Lived-Experience Council. Standing group of people with disability and families 
who co-design tools, review sentinel events and publish recommendations. 
• MPG (Multi-Person Guardianship) 
• NDIA  -  National Disability Insurance Agency. The Commonwealth agency that 
administers the NDIS. 
• NDIS  -  National Disability Insurance Scheme. Individualised funding for eligible 
participants. 
• NDIS Commission (NQSC). National regulator for NDIS provider quality, 
safeguards and the SIRS (reportable incidents). 
• Neuropsychology. Assessment and rehabilitation focused on cognition, behaviour 
and function after brain injury. 
• OPA  -  Office of the Public Advocate (Public Guardian in some jurisdictions). 
Statutory body safeguarding adults with impaired decision-making. 
• Speech pathology / Occupational therapy / Physiotherapy. Core allied-health roles 
in communication/AAC, cognition/ADL, mobility and participation. 
• Thriving Kids. Australian Government early-years foundational supports initiative 
for children (typically under 9) with mild-moderate developmental differences 
(including developmental delay and autism) and their families; complements, not 
replaces, the NDIS. 

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Diagnosis and conditions 
• GCS  -  Glasgow Coma Scale. Common acute measure of consciousness after brain 
injury. 
• PTA  -  Post-traumatic amnesia. Period of disorientation and memory impairment 
post-injury; a severity marker. 
• RLAS  -  Rancho Los Amigos Scale. Functional scale describing cognitive 
recovery/behavioural presentation after TBI. 
• Cognitive-communication. Communication difficulty arising from cognitive changes 
(attention, memory, processing speed, executive control). 
• Executive function. Planning, organising, initiating, shifting, monitoring and 
inhibiting behaviour. 
• Dysphagia. Swallowing difficulty; addressed via IDDSI and a Mealtime/Swallowing 
Plan. 
• Post-ictal. Recovery period after a seizure. 
Education, licensing and workforce 
• AQF  -  Australian Qualifications Framework. National levels system (e.g., Cert 
III/IV, Diploma). 
• ASQA  -  Australian Skills Quality Authority. Regulator for RTOs and VET 
quality. 
• TEQSA  -  Tertiary Education Quality and Standards Agency. Regulator for 
higher-education providers. 
• VET  -  Vocational Education and Training. Delivered via TAFE and private 
RTOs. 
• RPL  -  Recognition of Prior Learning. Recognises existing skill/experience; cannot 
waive safety-critical assessments. 
• CPD  -  Continuing professional development. Structured learning to maintain 
licence/registration. 
• Provisional licence. Time-limited IDC licence issued after core OSCEs/placements; 
converts to full licence on EPA sign-off. 
• Revalidation. Periodic reassessment (usually every three years); high-risk skills 
refreshed on 24-36-month cycles. 
• EPA  -  Entrustable Professional Activity. A real-world task a trainee is judged 
ready to perform with decreasing supervision. 
• OSCE  -  Objective Structured Clinical Examination. Station-based, observed test 
of practical skills (e.g., IDDSI setup, seizure response). 
• dOSCE  -  Decision OSCE. Observed simulation for tribunal/OPA decision-makers 
testing Reasons & Weighting, contradiction handling, least-restrictive analysis and 
attention/digital-health literacy. 
• Member Competence Passport. Record for tribunal/OPA members showing module 
currency, dOSCE recency/result band, calibration variance band and field-immersion 
status. Workforce competence KPIs (publish quarterly): 
competence_passport_currency_pct; dOSCE_pass_rate_pct. 
• Decision-Pause Rule. If a DSC Calibration Memo is pending, or a member’s 
Competence Passport is not current, only interim safeguards may be issued; no orders 
entrenching restrictive or screen-only routines may be finalised. 
• Scope of practice. Defined activities and limits for each role; scope is earned by 
observed competence, not titles. 

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• Delegation vs supervision. What may be delegated, to whom, and with what level of 
oversight; documented and observed. 
• Supernumerary shift. An over-and-above shift used for education or remediation, 
not counted toward ratios. 
Plans and attachments (standardised terminology) 
• PCP  -  Person-centred plan. The umbrella service/support plan owned with the 
person/family; operationalises goals and ties to verifiable practice (CPI timetable, 
IDDSI plan, seizure plan, medication responsibilities, AAC, travel, risk and 
safeguards). 
• NDIS plan. The funding instrument issued by the NDIA (not a service plan). It is 
informed by the PCP but is distinct. 
• Support plan / Individual Support Plan (ISP) / Individualised Support Plan / 
Individual Service Plan / Individualised Care Plan. Common labels used by 
providers; in this white paper these are treated as PCP equivalents. 
• IEP  -  Individual Education Plan. Education-system plan for school-age learners. 
In this white paper it is a PCP attachment where applicable, with goals mapped to the 
PCP timetable and CPI targets. 
• PCP attachments (examples, not exhaustive): 
◦ PBS Plan (with restrictive-practice governance and fade plan) 
◦ Mealtime/Swallowing Plan (IDDSI) 
◦ Seizure Management Plan (SMP) and rescue-med protocol (where permitted) 
◦ Medication Management Plan / Medication Chart (including PRN protocols; 
psychotropic stewardship) 
◦ Communication Passport / Communication Access Plan (AAC profile, partners, 
vocabulary sets) 
◦ Health Action Plan (HAP) / Annual Health Check (GP-led) 
◦ Personal Emergency Plan (all-hazards) 
◦ Advance Care Plan / Goals of Care 
◦ Cultural Support Plan (First Nations peoples/CALD) 
◦ Transition Plans (hospital discharge; school-to-work/SLES; custody release) 
◦ ILO Plan (Individualised Living Options, where used) 
◦ Employment/Micro-enterprise Plan (DES/SLES, where used) 
• Accessible plan. Plain English with Easy Read insert; names ordinary places, roles, 
steps, communication supports and dignity-of-risk notes. 
Practice and safety 
• Person-first practice. Seeing/supporting a person, not a label; goals, choices and 
rights lead the plan. 
• AAC  -  Augmentative and Alternative Communication. Tools/strategies 
supporting understanding and expression (gestures, pictures, devices). 
• PBS  -  Positive Behaviour Support. Uses functional assessment to teach skills, 
adjust environments and reduce restrictive practices. (Disambiguation: not the 
Pharmaceutical Benefits Scheme.) 
• IDDSI  -  International Dysphagia Diet Standardisation Initiative. Common 
language for food/liquid textures to reduce choking/aspiration. 
• Mealtime plan. Person-specific safety plan for eating/drinking (IDDSI level, posture, 
pacing, supervision). 

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• Seizure protocol / Seizure Management Plan. Steps for recognising, timing and 
responding to seizures; rescue-med thresholds; post-ictal care. 
• Medication reconciliation. Aligning all medicines at transitions (admission, 
discharge, handover) to avoid errors. 
• Psychotropic stewardship. Indication, target outcome and review date documented; 
taper/cease when no longer beneficial. 
• Low-arousal approach. Calm, minimal-demand methods to reduce distress and risk. 
• Quiet Hours. Pre-agreed low-stimulus periods in public venues (reduced noise, clear 
queues, AAC at counters). 
• Attention health & digital exposure. Planning to prevent prolonged, unsupervised 
device use from displacing participation, sleep, communication and learning; 
substitute with movement, social and learning activities. 
• Informed consent/assent. Supported decision-making tools used to understand 
choices, risks and alternatives. 
Restraint and least-restrictive practice 
• Least-restrictive practice. Always use the safest, least-limiting option to prevent 
immediate serious harm. 
• RP  -  Restrictive practice. Any practice limiting rights/movement; must be 
authorised, time-limited and reviewed. 
• Regulated restrictive practices (NDIS). Environmental restraint, physical restraint, 
mechanical restraint, chemical restraint, seclusion. Authorisation and availability vary 
by jurisdiction; where prohibited, this paper assumes zero use. 
• RP Panel. Mixed, time-limited authorisation panel independent of plan authorship; 
maintains expiry and fade-plan governance. 
• Environmental restraint. Restricting access to parts of the environment (e.g., locked 
doors/cupboards) under authorisation. 
• Seclusion. Supervised separation in a space the person cannot freely leave; used only 
for immediate risk and reviewed rapidly. 
• Mechanical restraint. Device-based restriction under strict clinical governance. 
• Chemical restraint. Medication primarily to control behaviour or movement (not 
ordinary treatment); requires oversight, timing and review. 
• Fade plan. Documented steps and dates to reduce and cease a restrictive practice. 
• 72-hour learning review. Rapid, post-event review after any restraint/sedation to 
capture learning and corrective actions. 
• Least-restrictive by default. Rights-based rule: use the least-restrictive option likely 
to work; log minutes if restraint occurs; run a 72-hour learning review; maintain a 
fade plan. 
Community inclusion and outcomes 
• CPI  -  Community Presence Index. Composite measure of presence in ordinary 
places: Frequency (how often), Variety (how many domains), Role Depth (observer 
→ role-holder). 
• Participation floor. Minimum expected out-of-home participation each week, with 
clinically documented exceptions and ramp-up. 
• Return-to-learn / Return-to-work. Staged pathways to resume education or 
employment after ABI/TBI. 

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• Local Inclusion Multiplier (LIM). Simple local indicator of inclusion-linked 
economic activity (visits, spend, roles, volunteer hours). 
• School-Age Navigation & Supports. IDC-led stream for 9-17-year-olds linking 
schools, families and community activities. 
• QOL  -  Quality of Life. Wellbeing across domains (health, relationships, roles, 
autonomy); tracked alongside CPI/participation metrics. 
• ICF  -  International Classification of Functioning, Disability and Health. WHO 
framework linking body functions/structures, activity, participation and environment. 
Tribunal, investigations and candour 
• MIS  -  Minimum Investigation Standard. Checklist of contacts, documents and 
credibility tests for guardianship/OPA investigations. 
• Contradiction Matrix. Table showing which claims agree/contradict and how 
conflicts were resolved. 
• Reasons & Weighting template. Structured decision: issues, options, evidence table 
(accept/reject/partial; weight and why), least-restrictive analysis, decision and 
conditions. 
• Independent-Reasoning Certificate (IRC). Decision-maker’s attestation that 
evidence was weighed independently and contradictions addressed. 
• Calibration Memo. Short DSC report summarising file-vs-field findings and 
variances; attached to Reasons & Weighting. 
• Second-reader safeguard. Additional member co-sign on high-stakes matters or 
where competence currency is uncertain. 
• Duty of candour. Professional obligation to be frank about facts, risks, errors and 
reasons. 
• VCAT / NCAT / QCAT / SAT (WA) / SACAT / TASCAT / ACAT / NTCAT. 
State/territory civil and administrative tribunals referenced throughout the paper. 
• ISBAR  -  Identify, Situation, Background, Assessment, Recommendation. 
Standard handover structure used in clinical/tribunal briefings. 
Data, integrity and transparency 
• Two-party e-receipt. Digital shift receipt confirmed by participant/nominee and 
worker, with time/date/location and plain-language description. 
• Roster-to-claim cross-check. Automated comparison of planned shifts vs billed 
claims to detect overlaps, impossible hours, travel anomalies and pricing errors. 
• Phoenix controls. Rules preventing sanctioned providers from re-entering under new 
entities. 
• Whistleblower protection. Confidential channels and legal protections for reporters 
of wrongdoing. 
• De-identified data. Data stripped of direct identifiers and aggregated/suppressed to 
protect privacy. 
• Immutable audit log. Append-only, time-stamped record of changes enabling 
reconstruction and accountability. 
• DPIA  -  Data Protection Impact Assessment. Privacy risk assessment for any data 
flow, dashboard or analytics model; mitigations logged. 
• PII  -  Personally Identifiable Information. Data that can identify a person 
directly/indirectly; protected under APPs. 

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• RBAC  -  Role-Based Access Control. Grant the least privilege required for role-
based access. 
• Kill-switch. Pre-defined trigger to pause an AI model or practice when harm/bias 
thresholds are crossed. 
• Bias and drift monitoring. Regular tests for unfairness or performance change in 
rules/models. 
• Open APIs/schemas. Published interfaces and data models that enable portability and 
audit. 
• E-receipts: privacy baseline. Pseudonyms only; no raw addresses or device IDs; 
optional coarse geohash with fuzzing. Records become append-only after 24 h using a 
hash-chain. Access is least-privilege; no tracking between visits. 
• OIDC/OAuth2. Open standards for secure identity and access. 
• HL7 FHIR  -  Fast Healthcare Interoperability Resources. Widely used health-
data standard for exchanging clinical information. 
• APPs / OAIC. Australian Privacy Principles enforced by the Office of the Australian 
Information Commissioner. 
• My Health Record (MHR). National system for sharing key health information; 
access is role-based with consent. 
• SPC chart. Statistical process control chart to spot signal vs noise over time. 
• DAG. Directed acyclic graph used to plan unbiased analyses. 
• Model card. Published description of purpose, data sources, limits, fairness checks 
and update cadence. 
• Shadow-mode. A model runs alongside human decisions for a defined period without 
affecting outcomes; results are evaluated before go-live. 
• Kill-switch & rollback. Technical and procedural stops to immediately disable a 
model and restore a last known-good state. 
Assessment and supervision 
• OSCE  -  Objective Structured Clinical Examination. Station-based, observed test 
of practical skills (e.g., IDDSI setup, seizure response). 
• Field observation. Direct observation in real settings by an authorised assessor. 
• Supervision ratios. Minimum mentor ratios (e.g., 1:8; 1:10) with reflective practise 
and observed sessions. 
• Double-rating (calibration). Two raters independently assess the same artefact/case; 
discrepancies reconciled and published as calibration stats. 
• Double-loop learning. Improvement that changes both frontline practise and the 
standards/tools that shape it. 
Economics and procurement 
• KPI  -  Key performance indicator. Measurable outcome tied to 
quality/performance. 
• ROI  -  Return on investment. (Benefits - Costs) ÷ Costs. 
• NPV  -  Net present value. Discounted sum of net benefits over time. 
• BCR  -  Benefit-cost ratio. Present value of benefits ÷ present value of costs. 
• CBA  -  Cost-benefit analysis. Formal comparison of costs and benefits with 
sensitivity testing. 
• Payback period. Time for cumulative net benefit to reach zero. 

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• Procurement ratio. Required percentage of IDC-licensed staff by role in 
contracts/registration. 
• Reasonable & Necessary (NDIS). Legislative test for funded supports tied to goals, 
evidence and value for money. 
Justice, emergency and handovers 
• Boundary protocols. Agreed rules for handovers between programs (e.g., Thriving 
Kids, IDC clinics, NDIS), including maximum times and minimum documents. 
• No-wrong-door. Any gateway service must triage and warm-hand over; no turn-
aways. 
• Handover pack. Minimum documents that travel with a person when services change 
(e.g., mealtime plan, seizure protocol, medicines list, contacts). 
• Continuity pack (30-day). Simple bundle at discharge/release to bridge the first 
month back in community. 
• Custody health. Health checks and safety plans used at police/corrections intake, 
including mealtime, seizure and AAC needs. 
• NSQHS Standards. National Safety and Quality Health Service standards for clinical 
governance and handover. 
• DAMA  -  Discharge Against Medical Advice. Process safeguards to ensure 
risk/choices are documented and supports arranged. 
• SIRS  -  NDIS Reportable Incidents Scheme. Notifiable incidents and time-bound 
reporting to the NDIS Commission. 
• ISBAR. Standard clinical handover mnemonic (Identify, Situation, Background, 
Assessment, Recommendation). 
Equity and access 
• First Nations. Aboriginal and Torres Strait Islander peoples. 
• CALD  -  Culturally and linguistically diverse. Communities with diverse 
cultural/linguistic backgrounds. 
• Auslan  -  Australian Sign Language. 
• Rural/remote. Communities outside major cities (ASGS remoteness areas). 
• Equity segmentation. Publishing de-identified outcomes by equity cohorts to detect 
gaps and drive closure plans. 
• On-Country. Supports/reviews conducted on Country with respect to local protocol 
and guidance, when desired. 
• Cultural safety. Practices that recognise and respect cultural identity (First Nations, 
CALD, Auslan access). 
• UNCRPD. UN Convention on the Rights of Persons with Disabilities; rights baseline. 
Abbreviations for agencies and venues (used in examples) 
• GP (general practitioner); ED (emergency department); MCH (maternal and child 
health services); ECE (early childhood education, e.g., kindergarten, preschool); 
RTO (registered training organisation). 
• DES  -  Disability Employment Services; SLES  -  School Leaver Employment 
Supports. 
Rural / regional / remote 

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• ACCHO  -  Aboriginal Community Controlled Health Organisation. 
• RFDS  -  Royal Flying Doctor Service. 
• RA1-RA5. ASGS remoteness areas: Major Cities (RA1); Inner Regional (RA2); 
Outer Regional (RA3); Remote (RA4); Very Remote (RA5). 
• Micro-hub. Small IDC team in a regional location running mobile clinics and hosting 
quarterly satellite OSCEs. 
• Standby. Paid availability period guaranteeing emergency coverage or loops despite 
thin demand. 
• Interpreter/AAC pool. Regional pool coordinated through micro-hubs; minimum 
service levels. 
 
Glossary (Key Terms) 
 
Practice & Safeguards 
• Least-restrictive practice. Supports are chosen and delivered to minimise restriction; 
restraint fades are time-bound and reviewed. 
• Dignity of risk. The person’s right to make choices that involve risk, with reasonable 
mitigation and learning reviews. 
• Two-Key Guardianship. MPG, IPP, Tier-0 Emergency, Will-and-Preferences 
(BIWP). 
• Two-party e-receipt. Claim transparency where the person/family receives a mirror 
of items billed by the provider. 
• 72-hour learning review. Short, time-boxed review after a serious incident focused 
on learning and prevention, not blame. 
• Sanctions ladder. Transparent escalations for non-compliance, paired with 
improvement supports. 
• Plain-English reasons. Short decisions published in accessible language (who 
decided, evidence relied on, why). 
Workforce 
• IDC pathway. Mapped study (or equivalency) + observed practise (OSCE/EPAs) + 
renewal on a 3-year cycle. 
• Equivalency & bridging. Credit for prior training/experience, with defined bridging 
modules to close gaps. 
• Tele-OSCE / micro-hub. Remote or small-site assessment/teaching arrangements to 
ensure rural parity. 
Data & AI 
• Shadow-mode. Model runs alongside human decisions for a defined period without 
affecting outcomes; results evaluated before go-live. 
• Kill-switch & rollback. Technical and procedural stops to immediately disable a 
model and restore a last known-good state. 
• Model card. Published description of purpose, data sources, limits, fairness checks 
and update cadence. 

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• Suppression rule (n<5). Privacy protection in dashboards where small counts are 
hidden or aggregated. 
• Human-in-the-loop. Models may flag, but no automated adverse decision (access, 
eligibility, pricing, safeguards) is permitted. 
Access & Equity 
• Independent coordination. Coordination separated from service provision to protect 
choice and manage conflicts of interest. 
• Cultural safety. Practices recognising and respecting cultural identity (e.g., First 
Nations, CALD, Auslan access). 
• Rural parity. Design choices that keep services viable and skilled in regional and 
remote communities. 
Symbols & Statistical Terms 
• κ (kappa). Inter-rater agreement statistic (chance-corrected). 
• G (Gwet’s AC1/AC2). Inter-rater agreement statistic less sensitive to 
prevalence/imbalance than κ. 
• n. Count; n<5 denotes suppression for privacy. 
 
 
Terms and definitions (alphabetical) 
Accessible plan. A Plain English plan with an Easy Read insert that states goals, supports and review 
dates. It names ordinary places, roles, practice steps, communication supports and dignity-of-risk 
notes. [See Service Model Standards  -  life in community.] 
Audit log (immutable). Append-only record of data events (create, read, update, export, permission 
changes) used to verify integrity and privacy compliance. [See Data, Dashboards and Privacy.] 
Community presence / participation. Presence = time in ordinary places; Participation = roles, 
relationships and contribution in those places. Both are required outcomes and are tracked. [See 
Service Model Standards  -  life in community.] 
Contradiction Matrix. A DSC tool that lines up File says / Field shows / Other sources and records 
the resolution and any residual uncertainty. [See Independent Verification Standard.] 
Cultural plan. A one-page addendum to a person’s plan covering Country, kinship, protocol, 
language and who should be present at key meetings. [See Equity, First Nations Partnership and 
Access.] 
Dignity of risk. Right to make choices and learn through reasonable risk with supports in place, 
rather than being over-protected in ways that shrink life. 
Double-loop learning. Improvement that changes both frontline practise and the standards/tools that 
shape it (not just fixing incidents). [See Evaluation & Continuous Learning.] 

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Double-rating (calibration). Two raters independently assess the same artefact/case to check 
consistency; discrepancies are reconciled and published as calibration stats. [See Evaluation & 
Continuous Learning.] 
Easy Read. Highly accessible summaries using large type, icons and short sentences. Paired with 
Plain English materials throughout this paper. 
e-receipt (two-party). Digital receipt confirmed by both the person/authorised representative and the 
provider for supports delivered. Includes accessible attestation modes and exception codes (e.g., E7 
Declined). [See Truth-by-Design Standard.] 
Exit & Entry Data Set. Minimum, standardised information that must move with a person when 
switching providers (goals, progress, communication supports, safeguards, upcoming commitments). 
[See Service Model Standards  -  life in community.] 
Fade plan. A short, time-bound plan to reduce and remove any restraint, naming alternatives, practice 
steps, supports and review checkpoints. [See Safety & Restrictive Practices Standard.] 
Family view. Role-based, person-level view of receipts, plans, reviews and progress available to the 
person and their authorised representatives. Distinct from public dashboards. [See Data, Dashboards 
and Privacy.] 
First Nations partnership MOU. A paid, local agreement with decision rights and escalation 
pathways for designing and delivering culturally safe supports. [See Equity, First Nations Partnership 
and Access.] 
Green / Amber / Red-light (restraint hierarchy). Graduated levels from least-restrictive alternatives 
(Green) to exception-only uses requiring high authorisation (Red-light). [See Safety & Restrictive 
Practices Standard.] 
Independent-Reasoning Certificate (IRC). Short DSC certificate describing scope, sources, 
observations, conflicts declared and variance summary, attached to published reasons. [See 
Independent Verification Standard.] 
Least-restrictive by default. Rights-based rule: use the least-restrictive option likely to work; log 
minutes if restraint occurs; run a 72-hour learning review; maintain a fade plan. [See Safety & 
Restrictive Practices Standard.] 
Micro-hub. Regional shared supervision and education site (and interpreter pool) enabling rural 
parity for IDC training/assessment and support delivery. [See Equity, First Nations Partnership and 
Access.] 
On-Country. Supports or reviews conducted on Country with respect to local protocol and 
community guidance, when desired. [See Equity, First Nations Partnership and Access.] 
Plain English. Clear, active, jargon-free language intended for broad audiences, paired with Easy 
Read where appropriate. 
Public tiles (dashboards). Quarterly, de-identified indicators (e.g., e-receipt coverage, restrictive 
minutes/1,000 hours) published with suppression rules and method notes. [See Data, Dashboards and 
Privacy.] 

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Reasons & Weighting (R&W). Structured decision document (issues, evidence table with probative 
weight, applied tests, findings, remedies/actions) enabling plain-English publication. [See 
Independent Verification Standard.] 
Red-team drill. Planned simulation (e.g., fraud ring, data breach, restraint spike, interpreter failure) 
used to test controls and publish lessons. [See Governance, Assurance and Risk.] 
Roster-to-claim cross-check. Automated matching of rosters, time-and-attendance, e-receipts and 
claims before payment, with exceptions routed to review. [See Truth-by-Design Standard.] 
Sanctions ladder. Proportionate consequences (advice → corrective plan → probation → suspension 
→ contract exit/referral) tied to verified findings, with publication rules. [See Truth-by-Design 
Standard.] 
Shadowing (dependency risk). Staff doing tasks for a person long-term rather than coaching with 
prompt-fading; reduces independence and participation. Addressed via IDC practise rules. 
Switching protocol. Low-friction process to change providers/coordinators with time limits, 
standardised data, and continuity safeguards. [See Service Model Standards  -  life in community.] 
Tele-OSCE / tele-review. Secure remote assessment/review modes used to support rural parity, 
complemented by required in-person observations across the renewal cycle. [See Workforce Standard  
-  IDC; Safety & Restrictive Practices Standard.] 
72-hour learning review. Mandatory review within 72 hours of any restraint use to test alternatives, 
update the fade plan, and reconcile medication and handovers. [See Safety & Restrictive Practices 
Standard.] 
Suppression rules / k-anonymity. Techniques for de-identification in public tiles (e.g., small-cell 
suppression, minimum group sizes) to prevent re-identification. [See Data, Dashboards and Privacy.] 
Verification (independent). DSC-led enquiry that reconciles file vs field facts and enables 
publication of plain-English reasons using R&W and the Contradiction Matrix. [See Independent 
Verification Standard.] 
“Screens-as-care” (anti-pattern). Over-reliance on screens/remote contact in place of real presence 
in ordinary places. Discouraged except for short, purposeful coaching. [See Service Model Standards  
-  life in community.] 
Workflows (event model). Standardised data events (e.g., receipt.created, restraint.logged, 
review.completed, dsc.published) used by APIs and audit logs. [See Data, Dashboards and Privacy.] 
Workforce levels (IDC). Progression from Foundation → Proficient → Advanced 
(supervisor/educator), each with defined supervision ratios, OSCE expectations and renewal 
requirements. [See Workforce Standard  -  IDC.] 
Standardisation note (used wherever plan names appear): 
In this white paper, PCP is the umbrella plan. “Support plan”, “ISP”, “Individualised Support Plan”, 
“Individual Service Plan” and similar labels are treated as PCP equivalents. IEP is an education-
specific attachment to the PCP. Clinical and safety documents (e.g., PBS Plan, IDDSI mealtime plan, 
Seizure Plan, Medication Plan, Health Action Plan) are maintained as PCP attachments, not 
substitutes. 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 370 
 
 
 
Acknowledgements & References 
 
With respect and gratitude to the people at the centre and those who stand with them every 
day: 
• People and families who shared lived experience that grounds this work - including 
First Nations families and communities who guided culturally safe practice. 
• Frontline practitioners (future and current Integrated Disability Clinicians) and 
supervisors across metro, regional and remote pilots. 
• Community-controlled organisations, providers and micro-hubs that opened their 
doors to observation, calibration and honest review. 
• Decision-makers and oversight bodies - tribunals, public advocates and program 
commissioners - who strengthened the verification and publication approach. 
• Equity partners - interpreters, Auslan professionals and AAC specialists - who 
ensured language justice. 
• Data, privacy and evaluation colleagues who kept integrity, safety and transparency 
at the core. 
Any remaining errors are the onus of the author. This edition is offered in the spirit of 
practical improvement and shared custody of change. 
 
 
How to cite this paper 
 
Zelen, G. (2025). Cognitive Disability Standards Refresh (ID/ABI): White Paper (Version 1.0, 25 
September 2025). Melbourne: public-interest submission. Licence: Text © 2025 ZELEN. G  -  CC 
BY 4.0. Schemas/templates: CC BY 4.0. Example payloads/data tiles: CC0 1.0. No organisation 
approved this work prior to release. _Not legal advice._ Prepared pro bono; see Conflicts & 
Independence in the paper. 
See repository README for details. Repository: 
https://sites.google.com/view/cognitivedisabilitystandards/home 
 
 
Citing example: 
 
Copy-paste (short form) 
Zelen G. Cognitive Disability Standards Refresh (ID/ABI): White Paper. Version 1.0  -  25 Sep 2025. Available at: 
https://sites.google.com/view/cognitivedisabilitystandards/home?authuser=1 
 
Optional (BibTeX) 
@report{Zelen2025CDSR, 
  author    = {ZELEN. G}, 
  title     = {Cognitive Disability Standards Refresh (ID/ABI): White Paper}, 
  year      = {2025}, 
  month     = {September}, 
  version   = {1.0}, 
  note      = {Version 1.0, 25 September 2025}, 
  institution = {Public-interest submission}, 
  url       = {https://sites.google.com/view/cognitivedisabilitystandards/home} 
} 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 371 
 
 
• Reports/white papers: Organisation Year. Title. Place (if relevant): Publisher. 
Version/date. 
• Legislation/standards/policy notes: Jurisdiction Year. Instrument title. 
Section/clause (if relevant). Date accessed. 
• Datasets/dashboards: Owning body Year. Dataset/Tile name (version). “Method 
notes” version. Date accessed. 
• Web sources: include author/organisation, year, title, site, and access date. 
• Personal communications or pilot artefacts (e.g., field notes) should be cited in-text 
as “personal communication” with date and stored in the program record, not 
reproduced publicly. 
 
 
 
Internal sources 
 
These documents informed or supply templates/schemas for the standards in this edition. 
Where a stronger template existed in the draft corpus, it has been lifted into the relevant 
appendix and duplicates elsewhere removed. 
1. A_DSC_IDC_Reform_Blueprint.pdf 
2. B_DSC_IDC_Policy_and_Legislative_Pack.pdf 
3. C_Audit_Information_Pack_Guardianship_OPA_Investigations.docx 
4. DSC_Proposal.pdf 
5. D_IMPLEMENTATION_ORDER.pdf 
6. E_DSC_IDC_Two-Key_Guardianship_Pack.pdf 
7. Frontline_HouseShift_Provider_Handbook_Exec.docx 
8. Frontline_HouseShift_Provider_Handbook_Coalface.docx 
9. No_Surprises_Handbook.docx 
10. Provider_Handbook.docx 
11. e_receipt_min_schema.json (aligned with Appendix E) 
12. dashboard_template.json (aligned with Appendix S) 
(Note: IDR_CBA_Workbook_V8_MinisterPack_Unlocked.xlsx is referenced 
methodologically in Finance & ROI Case and Appendix X  -  ROI Workbook Notes 
& Assumptions Register; values are sourced from the maintained workbook.) 
 
Additional external references 
 
• Disability Royal Commission - Final Report (12 volumes, 2023) - 
https://disability.royalcommission.gov.au/publications/final-report 
• Royal Commission into Aged Care Quality and Safety - Final Report (2021) - 
https://www.royalcommission.gov.au/aged-care-royal-commission-publications/final-report 
• Royal Commission into Victoria’s Mental Health System - Final Report (2021) - 
https://www.rcvmhs.vic.gov.au/mental-health-reform/final-report 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 372 
 
• UN Convention on the Rights of Persons with Disabilities (CRPD) - 
https://www.un.org/development/desa/disabilities/convention-on-the-rights-of-persons-with-
disabilities.html 
• Victoria - Charter of Human Rights and Responsibilities Act 2006 - 
https://www.legislation.vic.gov.au/in-force/acts/charter-human-rights-and-responsibilities-act-
2006/023 
• Queensland - Human Rights Act 2019 - 
https://www.legislation.qld.gov.au/view/whole/html/inforce/current/act-2019-005 
• NDIS Commission - Regulated Restrictive Practices Guide - 
https://www.ndiscommission.gov.au/resources/restrictive-practices 
• Aged Care Quality and Safety Commission - Minimising restrictive practices - 
https://www.agedcarequality.gov.au/safe-care/behaviour-support/minimising-restrictive-practices 
• ACSQHC - Medication Safety Standard (NSQHS Standards) - 
https://www.safetyandquality.gov.au/standards/nsqhs-standards/medication-safety-standard 
• WHO - Medication safety in transitions of care (2019) - 
https://www.who.int/publications/i/item/WHO-UHC-SDS-2019.10 
• Harden & Gleeson (1975) - Assessment of clinical competence using an OSCE (BMJ) - 
https://www.bmj.com/content/1/5955/447 
• ten Cate (2005) - Entrustability of professional activities and competency-based training 
(Medical Education) - https://onlinelibrary.wiley.com/doi/10.1111/j.1365-2929.2005.02341.x 
• AHPRA & National Boards - Aboriginal and Torres Strait Islander Health and Cultural 
Safety Strategy 2020-2025 - https://www.ahpra.gov.au/About-Ahpra/Aboriginal-and-Torres-
Strait-Islander-Health-Strategy.aspx 
• National Aboriginal and Torres Strait Islander Health Plan 2021-2031 - 
https://www.health.gov.au/resources/collections/national-aboriginal-and-torres-strait-islander-
health-plan-2021-2031 
• AS ISO 21998:2020 - Healthcare interpreting (requirements and recommendations) - 
https://www.standards.org.au/standards-catalogue/international/iso/AS%20ISO%2021998:2020 
• Speech Pathology Australia - IDDSI endorsement & resources - 
https://www.speechpathologyaustralia.org.au/SPAweb/Resources_for_the_Public/Eating__Drinki
ng_and_Swallowing/IDDSI.aspx 
• IDDSI Framework - Levels & testing methods - https:___/iddsi.org/Framework/ 
• OAIC - Guide to undertaking privacy impact assessments (PIAs) - 
https://www.oaic.gov.au/privacy/privacy-guidance-for-organisations-and-government-
agencies/guide-to-undertaking-privacy-impact-assessments 
• OAIC - De-identification and the Privacy Act (2024) - 
https://www.oaic.gov.au/privacy/privacy-guidance-for-organisations-and-government-
agencies/de-identification-and-the-privacy-act 
• ABS - Five Safes framework - https://www.abs.gov.au/statistics/research/technical-papers/five-
safes 
• Australian Signals Directorate - Event logging and monitoring guidance - 
https://www.cyber.gov.au/resources-business-and-government/maintain-security/event-logging-
and-monitoring 
• NIST SP 800-53 Rev.5 - Audit and Accountability (AU) controls - 
https://doi.org/10.6028/NIST.SP.800-53r5 

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• ANAO - NDIS: Fraud Control Program (performance audit) - 
https://www.anao.gov.au/work/performance-audit/national-disability-insurance-scheme-fraud-
control-program 
• Services Australia - Fraud Fusion Taskforce - https://www.servicesaustralia.gov.au/fraud-
fusion-taskforce 
• NDIS Commission - Compliance and enforcement actions register - 
https://www.ndiscommission.gov.au/resources/provider-registers/compliance-and-enforcement-
actions 
• NHS England - E-rostering good practice - https://www.england.nhs.uk/ourwork/nhs-
people/workforce-and-training/e-rostering/ 
• Angrist & Pischke (2009) - Mostly Harmless Econometrics - 
https://press.princeton.edu/books/hardcover/9780691120355/mostly-harmless-econometrics 
• Bernal, Cummins & Gasparrini (2017) - Interrupted time series regression for public health 
- https://doi.org/10.1093/ije/dyw098 
• Mitchell et al. (2019) - Model Cards for Model Reporting - https://arxiv.org/abs/1810.03993 
• Gwet (2008) - Computing inter‑rater reliability… AC1/AC2 - 
https://doi.org/10.1002/asmb.779 
Statutes and Standards - Quick Links by Jurisdiction 
Last checked: 25 September 2025 (AET). Links point to official legislation registers and 
tribunal sites. Where possible, prefer consolidated “in force” versions for operational use; use 
“as-made” for historical versioning and commencement tables. 
 
Commonwealth 
• National Disability Insurance Scheme Act 2013 (Cth). 
https://www.legislation.gov.au/C2025C00222 
• Disability Services Act 1986 (Cth). https://www.legislation.gov.au/C2024C00269 
• Privacy Act 1988 (Cth). https://www.legislation.gov.au/C2025C00228 
• Australian Consumer Law (Competition and Consumer Act 2010, Sch 2). 
https://www.legislation.gov.au/C2025C00197 
Victoria (Vic) 
• Guardianship and Administration Act 2019 (Vic). https://www.legislation.vic.gov.au/in-
force/acts/guardianship-and-administration-act-2019 
• Charter of Human Rights and Responsibilities Act 2006 (Vic). 
https://www.legislation.vic.gov.au/in-force/acts/charter-human-rights-and-responsibilities-
act-2006 
• Health Records Act 2001 (Vic). https://www.legislation.vic.gov.au/in-force/acts/health-records-act-
2001 
• Privacy and Data Protection Act 2014 (Vic). https://www.legislation.vic.gov.au/in-
force/acts/privacy-and-data-protection-act-2014 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 374 
 
• VCAT Practice Note PNG1 (Guardianship List). https://www.vcat.vic.gov.au/media/381/download 
New South Wales (NSW) 
• Guardianship Act 1987 (NSW). https://legislation.nsw.gov.au/view/html/inforce/current/act-1987-
257 
• NSW Trustee and Guardian Act 2009 (NSW). 
https://legislation.nsw.gov.au/view/html/inforce/current/act-2009-049 
• Privacy and Personal Information Protection Act 1998 (NSW). 
https:___/legislation.nsw.gov.au/view/whole/pdf/inforce/2025-08-12/act-1998-133 
• Health Records and Information Privacy Act 2002 (NSW). 
https://legislation.nsw.gov.au/view/html/inforce/current/act-2002-071 
• NCAT Procedural Directions & Guidelines. https://ncat.nsw.gov.au/publications-and-
resources/procedural-directions-and-guidelines.html 
Queensland (Qld) 
• Guardianship and Administration Act 2000 (Qld). 
https://www.legislation.qld.gov.au/view/html/inforce/current/act-2000-008 
• Public Guardian Act 2014 (Qld). https://www.legislation.qld.gov.au/view/html/inforce/current/act-
2014-026 
• Information Privacy Act 2009 (Qld). 
https://www.legislation.qld.gov.au/view/html/inforce/current/act-2009-014 
• QCAT Practice Directions (incl. guardianship participation PD 11/2022). 
https://www.qcat.qld.gov.au/resources/practice-directions 
South Australia (SA) 
• Guardianship and Administration Act 1993 (SA). 
https://www.legislation.sa.gov.au/lz?path=%2FC%2FA%2FGUARDIANSHIP+AND+ADMI
NISTRATION+ACT+1993 
• South Australian Civil and Administrative Tribunal Act 2013 (SA). 
https://www.legislation.sa.gov.au/lz?path=%2FC%2FA%2FSOUTH+AUSTRALIAN+%20C
IVIL+AND+ADMINISTRATIVE+TRIBUNAL+ACT+2013 
• Information Privacy Principles Instruction (PC012). https://www.dpc.sa.gov.au/resources-and-
publications/premier-and-cabinet-circulars/DPC-Circular-Information-Privacy-Principles-
IPPS-Instruction.pdf 
• SACAT forms, fact sheets and guides. https://www.sacat.sa.gov.au/about-sacat/publications-and-
resources/forms%2C-fact-sheets-and-guides 
Western Australia (WA) 
• Guardianship and Administration Act 1990 (WA). 
https://www.legislation.wa.gov.au/legislation/statutes.nsf/main_mrtitle_406_homepage.html 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 375 
 
• Privacy and Responsible Information Sharing Act 2024 (WA). 
https://www.legislation.wa.gov.au/legislation/statutes.nsf/law_a147470.html%26view%3Dco
nsolidated 
• SAT Practice Note 9 (Guardianship and Administration Act 1990). 
https://www.sat.justice.wa.gov.au/_files/practice_note9.pdf 
• Office of the Public Advocate (WA). https://www.wa.gov.au/organisation/department-of-
justice/office-of-the-public-advocate 
Tasmania (Tas) 
• Guardianship and Administration Act 1995 (Tas). 
https://www.legislation.tas.gov.au/view/pdf/authorised/2024-09-01%202024-09-02/act-1995-
044 
• Personal Information Protection Act 2004 (Tas). 
https://www.legislation.tas.gov.au/view/whole/html/inforce/current/act-2004-046 
• TASCAT Practice Directions. https://www.tascat.tas.gov.au/publications/practice-directions 
• TASCAT Guardianship Stream. https://www.tascat.tas.gov.au/guardianship 
Australian Capital Territory (ACT) 
• Guardianship and Management of Property Act 1991 (ACT). 
https://www.legislation.act.gov.au/a/1991-62/ 
• Health Records (Privacy and Access) Act 1997 (ACT). https://www.legislation.act.gov.au/a/1997-
125/ 
• Information Privacy Act 2014 (ACT). https://www.legislation.act.gov.au/a/2014-24/ 
• ACAT guardianship information. https://www.acat.act.gov.au/case-types/guardianship-and-
management-of-property-cases 
Northern Territory (NT) 
• Guardianship of Adults Act 2016 (NT). https://legislation.nt.gov.au/Legislation/GUARDIANSHIP-
OF-ADULTS-ACT-2016 
• Information Act 2002 (NT). https://legislation.nt.gov.au/Legislation/INFORMATION-ACT-2002 
• NTCAT rules and practice directions. https://nt.gov.au/law/courts-and-tribunals/northern-territory-
civil-and-administrative-tribunal-ntcat/ntcat-rules-and-practice-directions 
• Office of the Public Guardian (NT). https://agd.nt.gov.au/independent-offices/office-of-the-public-
guardian 
 
International instruments (for context and interpretation) 
• Convention on the Rights of Persons with Disabilities (CRPD) and Optional Protocol. 

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• CRPD Committee General Comments (esp. No. 1 on equal recognition before the law; No. 
5 on independent living; No. 7 on participation). 
• WHO International Classification of Functioning, Disability and Health (ICF). 
 
Common subordinate instruments & guidance (national) 
NDIS Rules and Operational Guidelines (plan management, guardianship interfaces, 
restrictive practices, behaviour supports). 
• NDIS Review  -  Final Report & factsheets (Navigators; Foundational Supports).  
• NDIS Amendment (Getting the NDIS Back on Track No. 1) Act 2024 (commenced 3 
Oct 2024) + explanatory updates.  
• NDIS Commission (mandatory registration direction - SIL, Support Coordination, 
platforms). 
Disability Royal Commission  -  Final Report (222 recommendations).  
National Cabinet / Ministers’ statements (Foundational Supports 50:50 design/funding 
intent).  
2025 “Thriving Kids” announcement (foundational supports for children outside NDIS).  
OAIC: Australian Privacy Principles Guidelines (APP Guidelines). 
 
Link hygiene note 
Prefer “in force”/“consolidated” pages for operational use. If a deep link changes, 
search the official register by Act title and year; verify the version date and record a 
new “Last checked” date. 
Conflicts and independence 
 
Independent verification (DSC) reports and published reasons are subject to conflict 
declarations and double-rating. Editorial control of this white paper rests with the Program 
Owner/Commissioner; evaluation partners retain the right to publish findings within privacy 
safeguards. 
 
Attribution statement 
 
Where language or templates were co-created with lived-experience contributors, First 
Nations partners, interpreters/Auslan practitioners, and frontline IDC candidates, this is 
acknowledged in the relevant appendix headers and in quarterly Quality Summaries. 
 
 
 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 377 
 
 
Stewardship, Data Publication & Author Exit (governance declaration) 
Custodian of record (post-publication) 
From v1.0 onward, custodianship of this work is transferred to an independent Custodian of 
Record appointed by collective consent of the convening partners (tribunal/registry, 
OPA/OPG, lead agency, First Nations partners, family peak bodies), chaired by an 
independent member. The author retires from all custodial and editorial roles at 
publication and does not approve or oversee subsequent changes. 
Appointment & term 
• Appointed by majority consent of the convening partners; conflicts declared and 
published. 
• 12-month renewable term; an acting custodian may be appointed for up to 90 days if a 
vacancy arises. 
• The custodian may be an organisation; a named officer is recorded as the contact. 
Scope of custodianship (minimum duties) 
• Maintain the canonical repository; mint releases/DOIs; keep CITATION.cff, 
CHANGELOG.md, and licences current. 
• Run the accessibility checklist; publish the tagged PDF and Easy-Read one-pager 
each release. 
• Govern schemas and tiles (Appendix E, Appendix S); manage versioning and 
deprecation notes. 
• Operate the open-justice cadence (reasons + R&W + tiles) per the hub section. 
• Triage errata; publish corrections and rationale; preserve prior versions and 
checksums. 
• Ensure legal deposit/preservation (e.g., NED/Trove, Internet Archive) is completed 
for each tagged release. 
Change control (transparent by default) 
• Semantic versioning: MAJOR for breaking changes; MINOR for additions; PATCH 
for fixes. 
• Major changes: 14-day public notice window unless urgent risk; record votes and 
reasons. 
• All changes must include a release note with what/why and backward-compatibility 
statement. 
Data availability and publication (custodian-governed) 
• Family view. Person-level receipts, plans, review summaries and progress are 
provided to the person and their authorised representatives via role-based access, with 
audit logs, accessible formats (including Easy-Read on request) and 
consent/withdrawal processes. 

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• Public tiles. De-identified indicators (coverage, safety, participation, verification, 
equity, sanctions) are published quarterly with suppression rules, method notes and 
“last checked” dates. 
• Release notes. Every update is versioned with a clear change log and rationale; 
archived copies with checksums remain available for audit; DOIs/permals are updated 
in CITATION.cff. 
• Preservation. Tagged PDFs and key artefacts are deposited for public record and 
discovery per the custodian’s preservation plan. 
(See Open reasons & appeal-ready records hub; Appendix E (schemas), Appendix S 
(dashboards), and README for accessibility and link-hygiene rules.) 
 
 
Author’s Conflicts & Independence 
 
Purpose of this statement 
This declaration helps readers understand the author’s position, relationships, and commitments that 
could reasonably be perceived to influence the work. 
 
Independence 
This white paper is a public-interest submission authored by ZELEN. G. It was prepared for the 
public good without commission or sponsorship. No organisation exercised editorial control over its 
content. 
 
Funding 
No external funding or in-kind support was received for drafting, editing, design, or dissemination. 
 
Current relationships 
• Paid roles with entities named in this paper: none.   
• Advisory/committee positions related to the subject matter: none.   
• Gifts, travel, or hospitality from entities named: none.   
 
Intellectual independence & reuse 
All recommendations, template texts, and schemas are published to invite scrutiny and reuse under the 
licences stated. Where evidence between “file” and “field” diverged, this is explicitly flagged using 
the Contradiction Matrix method, with sources cited. 
 
Scope limits & non-advice notice 
This publication is general information, not legal advice. Readers should consult the relevant 
legislation, practice notes, and local policy before acting. 
 
Corrections & updates 
Substantive changes are to be tracked in the repository CHANGELOG and/or release notes. 
Corrections or conflict updates can be requested via the future public issue tracker as per; 
[Stewardship, Data Publication & Author Exit (governance declaration)] 
 
 
 
 

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Afterword  -  Language, visibility, and what comes next 
 
This white paper closes with an unfashionable claim - likely true in a century, perhaps five: 
the smallest private stance scales. 
 
 
A quiet dismissal  - seems small in the moment, but it travels: from a room to a team, through 
a family, into a culture that someone else then has to endure. Often when we doubt another 
person, we’re rehearsing a doubt we already carry about ourselves. It leaks out as an eye-roll, 
a slow reply that never comes, a tired story about “people these days.” It feels subtle, even 
harmless, yet it lands hard: it shrinks the other person, erodes trust, and quietly gives us 
permission to hold back our effort. Most of the time the “other” isn’t trying to diminish you at 
all, but an offhand retort still has consequences. Life is short - none of us gets a special pass. 
If you decide it’s all for nothing, you’ll find evidence for that everywhere. Or you can choose 
a healthier way: to make things better on purpose - lighter, clearer, more decent - for those 
who cannot yet, and for those who are yet to arrive. That choice is ordinary, repeatable, 
contagious; it’s how cultures change. 
Jung taught us to recognise the shadow, but the future will ask more: to treat projection not as 
pathology alone but as a routine mirror check before we touch a person, or a policy. What 
you condemn in another is often your unexamined fragment looking back. The mature move 
is not to perform tolerance, but to name your shard, lay it down, and proceed. In such a 
civilisation, ethics is not theatre. It is infrastructure - like clean water or power - continuously 
available, quietly load-bearing, and missed only when absent. And because culture is a school 
with no recess, every act is curriculum: you are always learning, and (whether you intend to 
or not) always teaching. 
Dignity is the ground, not the garnish. Privacy, consent and pace are not extras we bring out 
on good days; they are the minimum standard on the worst days, when fear is high and 
choices are tight. “Least-restrictive by default” is more than a value statement - it is a clock 
we keep. If restraint happens at all, it happens only as a last resort, for the shortest possible 
time, with every minute accounted for, followed by a same-shift check and a plain-English 
explanation to the person and their supporters, and then a 72-hour learning review with a 
concrete fade plan. The aim is not to win an argument that restraint is bad; the aim is to 
become technically excellent at making it unnecessary - through communication access, 
environmental adjustments, pacing, skilled de-escalation, and clear roles so people know who 
is doing what and why. That is adult work. It asks for quiet competence and steadiness: 
noticing triggers before they flash, speaking simply and respectfully, making space, and 
protecting the person’s choices even when the room is noisy and time is short. When teams 
practise this, harm is prevented before anyone can put words to why the room feels safer and 
calm. That is the standard. 
We must stop confusing pace with worth. Some people receive the world the way a weak 
radio catches a station - static, then clarity. The humane response is not to scold the static; it 
is to reduce the noise. Fewer inputs, plainer cues, one step at a time, and a brief check-back in 
their own words. When understanding is late to arrive, we face a fork: read it as defiance, or 
adjust the setting so comprehension can take root. Choosing the latter is what grown societies 
do. 

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Usefulness beats niceness. Warmth without precision keeps problems intact; precise help, 
even when a little uncomfortable, moves lives. Pair evidence with empathy. If your numbers 
and a person’s dignity don’t line up, the problem is your method, not their humanity. The 
target isn’t optics; it’s durable capacity - skills and routines that still work tomorrow without 
you in the room. 
And for those who carry titles - judges, clinicians, principals, executives, officers - the test is 
simple: speak so the room can act. Lead with one plain sentence of purpose, then the steps, 
the choices, the “what if it goes wrong,” and the time and place of review. Trade acronyms 
for verbs. Give reasons anyone could explain to a neighbour. Ask for a teach-back: “Can you 
put this in your own words so I know I’ve made sense?” Put the reason in writing - with a 
name, a number, and the next step - and leave space for questions. Authority earns trust when 
it makes power legible and help actionable. 
When the person in front of you doesn’t speak the institution’s language - angry, halting, 
swearing, off-script - treat that as data, not disrespect. Never grade trauma for grammar. 
Separate heat from truth; extract the claim, the evidence, and the ask. Say, “I can hear this 
matters. Let me play back what I think you’re saying,” then summarise and check accuracy. 
Offer amnesty for language - no penalties for dialect, tears, or rough edges. Provide a 
navigator or advocate; pay them when you can. Document the decision and the reasons in 
plain English. Refuse the decorum tax - where polish buys credibility and pain is discounted 
for lack of jargon. Substance first, style second; people before protocol. 
A civilisation matures when it makes hate expensive and remedy cheap. Hatred often feels 
like a need because it is a shortcut. When people are overwhelmed - thrown by change, stung 
by humiliation, or scared by loss of control - the nervous system reaches for relief before it 
reaches for accuracy. Hate offers a quick conversion: uncertainty collapses and hardens into 
certainty, isolation flips into instant belonging, and helplessness masquerades as agency. In 
the body, that can feel like clarity, and in the moment it “works,” which is why so many of us 
reach for it. But it’s rented relief at a high interest rate. 
And what does this actually purchase? Affective relief, where pain becomes misguided 
action. Moral licence, where punishment feels righteous. Cognitive savings, where mixed, 
messy motives and partial causality are avoided. Status cover - private shame gets laundered 
as public certainty. And group credit - we belong without doing the slower work of building 
bridges. And what debt does it incur? Dehumanisation that makes later cruelty easier; policy 
errors that flow from simplified stories; vendettas that crowd out solutions; violence dressed 
as virtue; and, most corrosive, cultures that reward contempt over repair. The adult task is to 
price that shortcut correctly and make repair cheap: slow the moment, check the facts, widen 
the circle, and choose actions that reduce harm now and make the next encounter easier. That 
kind of clarity takes longer up front, but it compounds into safety, trust and competence - the 
real dividends of a advanced society. 
We will not sermonise our way there. We will build there: by auditing humiliation as if it 
were pollution, by giving grief lawful lanes, by mixing lives until strangers become co-
practitioners, by publishing reasons fast enough that outrage loses its only argument - that 
nothing else works. This is why hatred is best treated as a design failure, not destiny. Our 
systems too often make the hateful option cheap and the careful option expensive. If the 
fastest path to attention is contempt, and the slow path to remedy is clogged, people will take 
the fast road. Redesign the roads and the “need” drops. Slow mass outrage; speed fair 
process. 

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In practice, its like a type of covenant and it feels like this: you arrive and park your story, 
you breathe once long enough to turn judgment into description, you set a calm tempo and 
offer real choices, you do one concrete thing that reduces friction now - and you leave a trace 
others can copy. When you miss (and you will), you own it without theatre, apologise once, 
restore consent, and restart slower, clearer. This is what “teach by conduct” looks like. It 
rejects the fantasy that perfection is the point. Improvement in daylight is the point. 
Leaders are simply those who go first at repair. The sequence is stable: disclose, debrief, 
design a guard-rail, try again at the other’s pace. That loop - humility → repair → redesign - 
is more protective than any posture of certainty. It is how trust compounds. It is how quiet 
professions keep civilisations from tearing at their seams. And it is how the private vow of 
care becomes a public contract: everyone’s admitted debt, no longer “problem”, but a “design 
requirement.” 
Hold one sentence in view when fatigue tempts you to abbreviate the covenant: “if I am not 
making it easier, I am making it harder. There is no neutral gear.” Ease paid forward - 
privacy restored, capability built, dignity preserved - is the interest a civilisation earns on its 
intelligence. The cleverness of a people is the speed at which it updates; the wisdom of a 
people is the gentleness with which it proceeds at another human’s pace. The former can be 
simulated by machines; the latter is still ours to demonstrate. 
So we return to where this begins: your smallest private stance scales. Treat another’s 
vulnerability not as a verdict on their worth, but as a doorway to your growth. Name your 
shadow. Match the tempo. Choose the precise helpful act. Publish reasons. Consider hate as 
an artefact of weak design, then specify the hydraulics that make adulthood the path of least 
resistance. Learn in daylight. What follows will show the costs of forgetting - and the gains of 
remembering - this covenant. 
 
 
The threshold covenant… 
In concluding perhaps let me tell it as a story, because that’s how the first accounting was 
kept - around a fire, in memory, in the bodies of people who survived the season and those 
who didn’t. 
In the beginning, the village measured worth by what could be counted before winter: meat 
on the rack, grain in the pit, stones stacked against a flood. In that counting, speed looked like 
wisdom and strength looked like truth. A child who moved out of rhythm with the drumline 
of the day - who startled at light, who learned words like they were slippery fish, who needed 
time - a child unlike the others; asked the village to bend its tempo. Under a sky ruled by 
weather and luck, bending the tempo felt like blasphemy against scarcity. Councils of men, 
faces smoked and scarred, weighed the seasons aloud. Hunters spoke in verbs - run, lift, 
carry, fight. The quiet work inside the hut - feeding, soothing, scaffolding meaning one 
gesture at a time - was not yet a language they could hear. So the first debt was miscast: care 
was counted as delay; delay was priced as danger. 

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Still, there was a counterweight to the council: a mother at the threshold, holding the future 
close. She had already survived a trial the council did not have words for: months of being 
two people at once, the raw mathematics of blood and breath, the bargain with pain. In that 
arithmetic, love was not a feeling; it was a failsafe. Too much labour and hope had already 
been spent for her to accept the village’s small ledger. She pressed for inspection, for help, 
for change, long before those were disciplines. Around her gathered the fringe dwellers - the 
curious, the healers, the women with hands that could coax life from fever and milk from 
silence. They were not yet a profession. They were a circle, with a single rule: keep trying. In 
their hut, the child’s difference was a problem to be solved by attention. Outside, it was a sign 
to be read by fear. 
When sacrifice shows itself in public, the unknown walks in with it. People saw a mother 
keep vigil and felt a tug they could not name - was this holy or foolish? The world of limited 
firewood and thin harvests prefers a quick verdict, and difference seldom wins a quick vote. 
So a second drift began. Men who could not feel the tether mistook it for madness; 
neighbours misread patience as waste. The bond remained private, coded as women’s work, 
and the village built no structure to carry it. This was our species in its adolescence: 
ingenious with tools, clumsy with time; brave against predators, timid before tenderness; 
certain about gods and weather, baffled by the slow alchemy of learning. 
We then cloaked our discomfort in stories. Some said the gods were angry; some said a spirit 
had taken hold; some said the child was a test sent to weigh the tribe. These stories cut both 
ways. In one village, a shaman kept the child close, teaching them to wait, to watch, and to 
practise the old arts of wonder and wander. In another, the omen was taken as a mark to be 
hidden, held in wary respect, and deemed off-limits to inquiry. 
Across generations, the outcomes diverged. Where patience was ritualised, the circle widened 
and skill grew. Where impatience was sanctified, exclusion hardened into custom. The same 
river of human feeling ran beneath both. The difference was whether we built channels or 
walls. 
 
Centuries passed. Scarcity eased in fits and starts, then returned, then eased again. Empires 
rose, cities crowded, trade quickened the clock. And yet the old mispricing followed us into 
each new age. The work that held difference - slow coaching, low-arousal approaches, 
mealtime safety, seizure literacy, the humility to fade prompts - kept getting filed under 
sentiment. The village council had become an office, a parliament, a market floor, but the 
bias was unchanged: pay for spectacle, ask patience to volunteer. Professions that grew out of 
the hut carried the hut’s status - necessary, feminine, invisible. Even when they earned 
uniforms and titles, their wages remembered the first vote under the lean-to. 
We armed the mispricing with theories. “Survival of the fittest,” we said, grasping at Darwin 
like a weapon. We ignored the elephants who ring a calf, the dolphins who lift their young to 
breathe, the wolves who feed an injured packmate. We ignored our own record, too: 
outbreaks survived because nurses stood their ground; wars endured because someone kept 
mending bodies; economies recovered because teachers, quietly, rebuilt minds. We preferred 
the story where the hero is fast and loud.  
The tale where the hero sits still long enough for another nervous system to synchronise, felt 
too small for the stage. 

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Across the long arc, the child is still with us - no longer miscast as the “eternal child”, but 
recognised as a person, yet still shadowed by a stigma that should never have existed. For 
some, the world arrives a half-beat late and out of order - like subtitles that drift from the 
film. Words come; meaning lands after the moment has moved on. Before any task begins, 
there is already a tax to pay: sorting glare, filtering noise, decoding faces that change faster 
than the sky. By afternoon, the ledger of small costs is full. From the outside, it is easy to 
name this indifference or defiance or cycles of deviancy. From the inside, it is endurance - a 
resilience most of us are never asked to cultivate. 
In the old village, there was no word for latency; there was only a sense that the child would 
not “keep up.” We have the word now, and still we punish the lag as character. That is not 
maturity. It is a habit we forgot to unlearn. 
The plain truth - simple, human, and close to shame - is this: the many of us who live outside 
the daily reality of such ‘difference’ carry a single, crude picture when the subject arises. We 
don’t imagine the plethora of complexities in the slow building of everything from language 
through to the careful coaching of something as simple as sleep; we reduce the whole field 
and industry to toilet care - and recoil. “Who,” we ask - other than a parent, and even then not 
always - “would choose to wipe a stranger’s bottom?” The thought feels unsayable in polite 
rooms, so we laugh it off or fall quiet. We forget that each of us performs this act for 
ourselves almost daily, and that the distance between “me” and “someone who cannot yet” is 
not moral but circumstantial - and often temporary. 
But the real work is not confined to a toilet. It is maturity about circumstance. It is evolution. 
It is complex teaching - patiently and proficiently - a sequence that preserves dignity for a 
lifetime, that those outside of the field simply never consider: noticing the signal; planning 
the route; managing clothing and balance; cleaning well; washing hands; resetting calm; 
returning to the day. It is infection control and privacy; sensory regulation in a small, echoing 
room; AAC cues when words are scarce; patience when the body is frightened or the timing 
is a beat off. The goal is not simply a clean moment; the goal is independence.  
That takes real time, expertise, supervision, and respect - exactly the things our old ledgers 
underfunded because the task looked “dirty” instead of clinical, essential, human. 
Those who step toward this vulnerability - who treat another’s need as a doorway rather than 
a verdict - learn something larger than care: that connection is not merely medicine for the 
self alone, but the substance of what we all are. We all get our hands dirty in life. The point is 
not to deny it; it is to turn that shared fact into a heightened perspective, beyond craft, a 
future-proofing aptitude that restores privacy, builds capability, and lets more of us move 
through the day unescorted. 
Who steps up when most step back? Not only mothers, fathers, nurses and volunteers. Often 
it is the people our societies misname as marginal - workers on the edges, migrants, the 
quietly stubborn - who understand that the world is bigger than the self and that civilisation is 
measured in how we guard one another’s privacy and pride at our most vulnerable. We have 
been wrong to read this as low status. Accomplished appropriately, it is a high competence 
with a low wage. 
 
 

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A witness voice - call it the scribe who sits one pace back from the epistemological fire and 
offers the plain account beneath the story. We undervalued this work not because it lacked 
worth, but because our early ledgers were written by those who did not stand at the threshold 
of the hut. Fear and scarcity taught us to count what moved quickly. Misaligned levels of 
patriarchy taught us to discount what moved quietly. Anthropocentrism taught us to despise 
what did not look like us, think like us, or keep our pace. Those three tutors - fear, scarcity, 
pride - graduated into policy. Once policy hardens, architecture follows: institutions built to 
contain rather than nurture, pay scales that make care a vow of poverty, training that arrives 
late and thin. 
And yet the mother’s covenant - the overdue bridge that welcomes whichever hands will join 
in crossing this threshold - remains the most adult work we do. It is not soft; it is engineering. 
It slows the clock until two tempos can meet. It publishes what matters - minutes of restraint, 
days in ordinary places - and learns fast from failure. It proves that the quiet professions keep 
civilisations from tearing at their seams. Adolescence ends when the village - now society - 
rewrites its ledgers: when care moves from private vow to public contract, from largely 
women’s unpaid burden to everyone’s acknowledged debt, from ‘blessing/curse’ to ‘design 
requirement’. We are late to that rewriting. We are not too late. 
 
In our story, as the scene widens. The streetlight has long replaced the fire. The hut is a 
kitchen, a clinic, a shed, an office, a factory, a lab, an online portal. The village is a city that 
hums and stutters, full of signal and haze. The counting is louder than ever - likes, clicks, 
dollars, cases, codes - but the old error still haunts the tally. And yet, everywhere, quiet 
achievers move the ledger grain by grain. 
In one back shed, a teenager learns the patience of solder: a cheap 3D printer chattering 
beside jars of screws; a prosthetic wrist taking shape layer by layer. In another, a robotics 
club reworks an exoskeleton so it tunes itself to gait and fatigue, not spectacle. In a library 
after hours, a volunteer shows a room of strangers how to caption their own videos so elders 
can hear with their eyes. At the local TAFE, a tutor builds a micro-credential that treats 
“support worker” as clinician, pairing low-arousal practice with seizure first-aid and safe 
mealtimes. Men’s Sheds repair mobility devices between stories; cousins in a granny flat 
hack together DIY air-quality sensors and post the graphs for their street. On Country, 
rangers walk with satellites and story, reading fire with both. 
Frontline rooms carry the same light. A nurse replaces a brittle checklist with a handover that 
actually asks: what calms, what frightens, what works when nothing else does? An ambo 
crew reviews the one minute before a restraint - not to defend it, but to find the first fork 
where another choice could have been made. A teacher co-designs an AAC board with a 
family and stops calling paperwork “care.” In a small clinic, a rural GP keeps a pocket 
ultrasound and a long memory for people’s lives, knowing both will save a trip to town. 
Further up the hill, labs and super-structures hum. A synchrotron images materials that will 
make sensors smaller and cheaper, another to study the structure of viruses and proteins. A 
hospital biobank shortens the road from suspicion to diagnosis. A clean room prints the next-
gen chip that will sit in a wearable and whisper to a phone, “Stand up now, before dizziness 
becomes a fall.” National compute runs protein models at breakfast and climate models by 
lunch. Civic-tech teams publish open dashboards that let families track the care that matters. 

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Start-ups write glue code that lets old systems speak, and open-source contributors fix a 
critical bug at 2am without bothering to sign their names. 
Youth of today still remain potential and are not a problem to be solved; they are the proof 
that adaptation is native. For every loud harm, there are nine quiet repairs. Students mentor 
peers they will never meet. Young carers teach officials to write letters people can actually 
read. Under-25 founders ship tools that work, then answer emails at midnight because 
someone needed the fix. Early-career clinicians refuse to let “the computer says no” pass for 
care. Their distractions are many, their feeds are noisy, their worlds are complex - and they 
are still ahead of their time, because by design, they are the prospects for success, the 
advanced quiet achievers. 
It is activation time. The season is acceleration. For those of us born earlier, we actually are 
living in the future. Pathogens are sequenced in regional labs. CRISPR-class edits face down 
blood disorders once thought immovable. Lab-on-a-chip rides to the bedside in a pocket. 
Neural interfaces give back a voice; rehab robotics remember that fatigue is a clinical sign, 
not a failure of will. Organoids test drugs so fewer bodies have to. Blood tests at point-of-use 
shrink the queue at ED. AI designs pharmaceuticals overnight and helps triage and roster the 
next, reducing waits without reducing people to codes. Fraud detectors protect honest 
providers so the trust can flow again. Multimodal captioners open doors for those in the 
communities that cannot hear; translation whispers across languages and into Easy Read. 
Digital twins pressure-test policy, and simple e-receipts with plain-English reasons rebuild 
the kind of confidence the old hut carried without paperwork. 
As a majority we tend to focus on the latest media coverage, usually, predominantly negative, 
but many of us have already sourced alternatives in private positive feeds. Mesh networks 
and low-Earth satellites keeping remote clinics online. Live captioning and AAC are 
everywhere we will let them be. Data are shared with restraint and precision so teams can 
coordinate without stripping anyone bare. Dashboards are written in the language of families 
and frontline staff, not committees. Perovskites and rooftops make houses net-positive; 
batteries even out the peaks; greener materials rebuild the places we broke. Farms save water 
and soil by noticing again. Micro-mobility gives streets back to people. Competence is 
measured in what we can actually do in the room, not what we claim on a form. Simulation 
labs let people practise the moments where harm loves to hide. Rural scholarships and tele-
OSCEs make “far” less of a sentence. 
And still, while these gardens are being planted, the old wars of pride and the old worship of 
speed stagger on. Starvation keeps its passport. Mainstream media grows into a revenue-
driven demigod. Thin lives pass for normal. Much of it remains, to our shame, legal. That is 
the part of the story where the narrator looks up from the page and says: this is not fate. This 
is design. And design can be changed. 
Which brings us to you. 
You have abilities, attributes, potential - a proven record whether or not you have named it 
that way - time, energy, resources you may not yet have recognised. They do not need to 
remain dormant. In a world this complex, a small, well-aimed act is not small. Write the 
letter. Share the prototype. Convene the meeting that should have already happened. Clean 
the dataset. Join the rostering fix. Add the safeguard. Restore a dignity. Start where your 
hands already are; then widen the circle by one more person. 

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No one alive can prove what this life “is about” with the kind of certainty that silences 
questions. Very few of us are at our best consistently, and no one person knows best. What 
we do know - what the first mother at the threshold knew - is that we get through by helping 
one another pace the day. The first exclusion was an error of accounting made by frightened 
geniuses. The repair is an act of maturity. Pay for what holds the world together. Teach it. 
Supervise it. Renew it. Tell the story so the next council, in whatever clothes it wears, 
remembers the hut as the place where our species first learned to be more than clever - where 
we learned to be human at the pace another human needs. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

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Words 
Words build the scaffolding we stand on. For decades we were taught to move from labels 
like handicapped and retarded to person-first language - person with a disability. It was a 
necessary shift. Yet many of our current terms (cognitive disability, intellectual disability, 
acquired brain injury/damage) still cue the reader to search for the problem in the person. 
Language can constrain like that. It can also liberate - meeting us exactly where connection is 
needed. 
This paper keeps statutory terminology where rights and precision matter. Laws, funding 
instruments and accountability systems still speak those words, and people’s entitlements 
must be protected in that register. At the same time, if we are serious about evolving as a 
species - socially, ethically, institutionally - we need frames that focus on fit: person, body, 
brain, communication, and the environments we design. That isn’t euphemism; it’s 
operational truth. When the frame shifts from ‘deficit in a person’ to ‘mismatch to be solved’, 
different decisions follow - about training, design, supervision, risk, and everyday presence in 
public life. 
With that in mind, here is a working lens I will explore elsewhere. It is not adopted across 
this Standards Refresh; it is an invitation to think forward. 
CEEN  -  a new word, a new way 
Pronounced: “seen” 
Definition (first use): 
People with CEEN (Cognitive-Embodied & Environmental Needs)  -  a respectful umbrella term for 
people whose cognitive processing, executive function, communication, sensory/embodied 
experience, or environmental demands require consistent supports. This encompasses groups 
traditionally described as having intellectual disability, acquired brain injury and related profiles, and 
is recognised as disability under the Disability Discrimination Act/NDIS Act and equivalent state 
laws. 
Why this works 
• Affirming, not deficit-led. Centres the fit between person and environment, not a problem in 
the person. 
• Whole-person + context. “Cognitive-Embodied & Environmental” explicitly includes brain, 
body, communication, sensory processing and the surrounds (design, routines, supports). 
• Operational. Maps cleanly to standards, OSCEs, funding and accountability without 
euphemism. 
• Memorable meaning. Sounds like “seen” or “scene” - aligning with the theme of visibility 
and with a cultural sense of belonging (a scene as the shared environment for a practice or 
interest). 
 
If a better term emerges from communities, families, frontline workers and scholars, we should adopt 
it. Language should keep pace with our practice - and our practice with people’s lives. 

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Appendix AZ  -  Legal, Risk & Publication Basis 
Owner: Custodian of Record (post-publication) 
Interfaces: Tribunal/Registry, OPA/OPG, Lead Agency, First Nations partners, Family 
peaks, Analytics 
Purpose 
Collect in one place the conditions of use, risks and mitigations, governance, and publication 
rules that apply to this work and its artefacts. 
A. Non-reliance / No-duty (plain-language clause) 
Users must not rely on this publication as advice or instruction for a specific case. No duty of 
care is assumed to any person in respect of decisions made using this material. 
Implementation remains the responsibility of the decision-maker under local law, practice 
notes, ethics rules and organisational policy. 
B. Scope limits 
Not legal advice; not clinical guidance; not a substitute decision; not professional services. 
Emergency care takes precedence: act to make safe, then document and review within stated 
timeframes. 
C. Jurisdiction 
Legislation and practice vary across states/territories. Always confirm in-force sources (and 
record “last checked” dates for external links). 
D. Privacy & data handling 
No person-level publication. De-identify, suppress small numbers (<5), maintain immutable 
audit logs, complete DPIAs where required, and prohibit re-identification attempts. Breach 
response: notify custodian; follow statutory reporting. 
E. Defamation & sub judice hygiene 
No commentary on identifiable individuals or live proceedings. Generalise examples; remove 
case-specific details; use de-identified composites. 
F. Publication cadence (open justice) & records 
Appeal-ready records (reasons + R&W + Contradiction Matrix + IRC + exhibits schedule) 
govern timing. De-identified reasons + tiles are published quarterly with method notes and 
suppression rules. 
G. Change control & provenance 
Semantic versioning; release notes; checksums; DOI minting; tagged PDF + Easy-Read each 
release; archived copies retained. Major changes require public notice unless urgent. 
H. Custodianship 
From v1.0 the Custodian of Record maintains the repository, licences, schemas/tiles, link 
hygiene, and legal deposit/preservation. The author has no custodial or editorial role post-
release. 

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 389 
 
I. Conflicts & independence 
Declare and manage conflicts for custodians, editors, and contributors. Providers/paid 
supporters must not act as keys/guardians on conflicted matters. 
J. AI & automation limits 
Analytics and prompts may flag issues; a named human decides. No automated decision-
making for consequential outcomes. 
K. Notice & takedown (contact) 
Report alleged breaches (privacy, defamation, copyright, errors) to: <contact>. The custodian 
acknowledges within 5 business days; urgent risks triaged within 24 hours. 
L. Licences & reuse 
Text: CC BY 4.0; schemas/templates: CC BY 4.0; examples/sample data: CC0 1.0; code 
snippets: MIT. No warranties. Cite the canonical DOI and version. 
M. Records of appointment 
Minute of the custodian’s appointment (date, parties, term, conflicts) is appended here and 
updated on renewal. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

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Historical core v1.0 · 25 September 2025 · PDF page 390 of 390. Reform proposal, not current law or clinical instructions. Check tables, symbols and citations in the original. Source: ZELEN, G · CC BY 4.0; Care Continuity text extraction and navigation, 27 October 2026.

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COGNITIVE DISABILITY STANDARDS REFRESH (ID/ABI) · V1.0 - 25 SEP 2025 · © ZELEN. G· CC BY 4.0 390 
 
 
 
 
 
 
 
Dedication 
 
For my beautiful son, my diamond in the rough; the most resilient person I have ever met, 
who taught me how to think when things weren’t right: “The rules of goodness, Dad.” 
 
This paper is for him, and for everyone who moves at a different tempo. May those rules 
guide what we build next, so people are seen, safety is proven, and belonging is practised in 
ordinary places every day. 
 
 

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