AAccess SupportAllied Health

Policy

Conflict of Interest Policy

How we identify, declare and manage actual, potential and perceived conflicts of interest so that your choice and control always come first.

All policies

1. Purpose and scope

Ametz Group pty ltd. T/A Access Support (“Access Support”, “we”, “us”) must act with integrity, honesty and transparency. This policy sets out how we identify, declare, record and manage conflicts of interest so that participants keep genuine choice and control over who delivers their supports.

It binds all key personnel, directors, employees, students, contractors and volunteers, and applies to referrals, procurement, recruitment, quoting, assessment and report writing.

2. Definitions

  • Actual conflict — a private interest that does influence, or has influenced, a decision affecting a participant.
  • Potential conflict — a private interest that could influence a decision in the future.
  • Perceived conflict — circumstances in which a reasonable person could believe a decision was influenced by a private interest, even if it was not.
  • Private interest — financial interest, business or referral relationship, secondary employment, family or personal relationship, gift, benefit or hospitality.

3. Common conflicts in allied health

  • Recommending assistive technology, equipment or home modifications supplied by a related business or a supplier that provides us with benefits.
  • Delivering both support coordination (or plan management) and therapy to the same participant.
  • Writing a functional capacity or plan review report that recommends more of our own services.
  • Accepting or offering gifts, commissions, referral fees, sponsorships or incentives connected to referrals.
  • Treating a family member, close friend, employee or a person we have a personal relationship with.
  • Secondary employment with another provider that competes for the same participants.
  • Recruitment or procurement decisions involving a relative or associate.

4. Our commitments to participants

  • We will always tell you, in writing and in a format you understand, when we have an interest in a service we are recommending.
  • Where a referral is needed, we offer at least two or three options where they exist, including providers we have no relationship with, and we never charge or accept a fee for a referral.
  • You may accept or decline any recommendation, choose another provider, or change or leave Access Support at any time without penalty and without affecting other supports.
  • Assessments and reports state the clinical evidence and rationale for every recommendation, and clearly disclose where we would be the service provider.
  • Where we deliver support coordination and therapy, the roles are held by different workers with separate reporting lines, and the participant's written informed consent is obtained.
  • You can use an advocate, nominee or independent second opinion at any point, and we will help you find one.

5. Declaration process

  • All key personnel and workers complete a Declaration of Interests at induction, annually, and within 5 business days of any change.
  • A conflict arising in a specific case must be declared to the Director before the next service is delivered.
  • The Director records the declaration in the Register of Interests, decides on a management strategy, and documents it in the participant's file.
  • A signed Conflict of Interest Declaration is given to the participant and a copy retained on file.

6. Management strategies

  • Disclose — inform the participant and record the disclosure.
  • Separate — allocate the work to a different clinician or team with independent supervision.
  • Recuse — remove the conflicted person from the assessment, quote, recommendation or decision.
  • Independent review — obtain an external clinical opinion or competitive quotes.
  • Refuse or refer — decline the work and refer the participant to an unrelated provider where the conflict cannot be managed.
  • Escalate — notify the NDIS Commission or relevant funder where a conflict is serious or cannot be managed.

7. Gifts, benefits and hospitality

  • Workers must not solicit gifts, money, tips or benefits from participants, families or suppliers.
  • Token gifts of nominal value (under $50) may be accepted with the Director's approval and must be recorded in the Gifts and Benefits Register.
  • Cash, gift cards, loans, discounts, inheritances, bequests and personal financial arrangements with participants are prohibited.
  • Commissions, kickbacks and volume-based incentives from suppliers or other providers are prohibited.

8. Register of interests and records

  • The Register of Interests and the Gifts and Benefits Register are maintained centrally by the Director.
  • Both registers are reviewed at least quarterly and at every management meeting, and are available to auditors and the NDIS Commission on request.
  • Declarations and management plans are retained for at least 7 years.

9. Breaches

Failing to declare or manage a conflict is a breach of the NDIS Code of Conduct and of this policy. It is managed under our disciplinary procedure and may result in retraining, removal from a case, termination, and notification to the NDIS Commission or a professional body such as AHPRA or Speech Pathology Australia.

10. Raising a concern

If you think a recommendation was influenced by our own interests, tell us on 0485 835 045 or ah@accesssupport.au. You can also contact the NDIS Quality and Safeguards Commission on 1800 035 544. Concerns can be raised anonymously and we will not retaliate.