NDIS Code of Conduct Allied Health: Obligations for Therapy Workers

Allied health workers operating within the NDIS face a distinctive compliance challenge. The NDIS code of conduct allied health obligations sit alongside — and sometimes in tension with — existing professional registration requirements under AHPRA. Furthermore, most therapy workers move between multiple practice settings, which makes consistent compliance harder to achieve. As a result, occupational therapists, physiotherapists, speech pathologists, and psychologists must understand both their NDIS obligations and their professional duties. This guide breaks down every layer of those requirements, identifies the most common compliance gaps, and explains how to build a system that satisfies both regulators simultaneously.

Whether you work for a registered NDIS provider, run your own private practice, or operate as a sole trader, this guide applies to you. The NDIS Code of Conduct covers all workers who deliver supports to NDIS participants — registered or not.

For a broader overview of the Code that applies to all providers, see our complete NDIS Code of Conduct guide for providers.

What Is the NDIS Code of Conduct Allied Health Framework?

The allied health code of conduct under the NDIS is the set of seven behavioral obligations that all NDIS workers — including therapy workers — must follow. It is enforced by the NDIS Quality and Safeguards Commission and applies universally, regardless of registration status. Allied health workers additionally carry obligations under their AHPRA-registered profession’s own code of conduct, creating a dual compliance framework that requires careful management.

The Seven Core Obligations Under the NDIS Code

The NDIS Code of Conduct outlines seven specific behavioral obligations. Each one applies directly to therapy workers and to the organisations that employ them.

1. Respect Individual Rights and Independence

Allied health workers must actively support participants’ right to make decisions about their own lives. In clinical settings, this means presenting options rather than directives. Moreover, it requires that therapy goals are set with the participant, not merely for them.

Therapy workers must also respect cultural, linguistic, and personal identity. Consequently, assessment tools and communication approaches should be adapted to each participant’s needs and preferences.

2. Respect the Privacy of People With Disability

Therapists routinely handle sensitive clinical information. Therefore, privacy obligations under the NDIS Code align closely with the Australian Privacy Principles and relevant state health records legislation. However, dual compliance requires care: AHPRA codes also impose strict confidentiality duties on registered practitioners.

Progress notes, assessment reports, and session records must all be handled securely. In addition, sharing clinical data with other team members requires participant consent unless a legal exception applies.

3. Provide Supports in a Safe and Competent Manner

For allied health workers, this obligation is particularly significant. It requires that you only deliver services within your professional scope of practice. Furthermore, your clinical skills must remain current through ongoing professional development.

This obligation intersects directly with AHPRA registration requirements. As a result, if your professional registration lapses or is suspended, you cannot lawfully deliver NDIS supports — even if your employment contract continues.

4. Act With Integrity, Honesty, and Transparency

Allied health workers must not make false claims about qualifications, experience, or service outcomes. Moreover, billing practices must accurately reflect the services delivered. Consequently, claiming for sessions that did not occur, or billing a higher support category than was actually provided, constitutes both a Code breach and potential fraud.

Transparency also applies to conflicts of interest. Therefore, if you recommend assistive technology from a supplier in which you hold a financial interest, you must disclose that relationship.

5. Promptly Raise and Act on Concerns About Safety or Quality

Therapy workers have a specific duty to speak up when they observe unsafe practices. This applies even when the concern relates to a colleague or employer. However, many allied health workers feel hesitant to report upward. As a result, organisations must build genuine psychological safety into their governance structures.

Furthermore, this obligation requires action — not just disclosure. If you raise a concern and no action is taken, you may need to escalate to the NDIS Commission directly.

6. Take All Reasonable Steps to Prevent Violence, Abuse, Neglect, and Exploitation

Allied health workers often work one-on-one with participants in community or home settings. Therefore, this obligation carries heightened significance for therapy workers. In addition, the duty extends to recognising signs of abuse perpetrated by others and taking appropriate action.

Mandatory reporting obligations vary by state and territory. Consequently, therapy workers must be familiar with both NDIS Commission requirements and applicable state child protection or adult safeguarding laws.

7. Take All Reasonable Steps to Prevent and Respond to Sexual Misconduct

This obligation is absolute. There are no circumstances under which sexual contact with a participant is permissible. Moreover, AHPRA codes for all registered health professions carry identical prohibitions. As a result, a breach in this area will typically trigger both NDIS Commission action and professional deregistration proceedings.

Organisations must have clear policies, complaint pathways, and staff training addressing this obligation. In addition, workers must understand their own reporting duties when they become aware of sexual misconduct by a colleague.

How the Allied Health Code of Conduct Works in Practice

Understanding the obligations in theory is the first step. However, applying them consistently across diverse clinical settings requires structured systems and ongoing attention.

Working in Community Settings

Many allied health workers deliver NDIS supports in participants’ homes, schools, or community venues. Consequently, the usual clinical safeguards of a hospital or clinic may not be present. Therefore, therapy workers must apply their professional judgment even more carefully in these environments.

In addition, lone-worker policies become essential. Employers must have procedures for checking on workers who conduct solo home visits. Furthermore, risk assessments should be completed before entering new environments.

Telehealth Delivery

Telehealth has become a significant mode of therapy delivery for NDIS participants. Moreover, it introduces specific compliance considerations. Privacy obligations require that sessions are conducted in secure environments on both ends of the connection. In addition, informed consent for telehealth must be obtained and documented.

For NDIS billing purposes, telehealth sessions must be delivered in accordance with the relevant NDIS Support Catalogue line items. Therefore, billing codes and session documentation must reflect the telehealth modality accurately.

Group Therapy Sessions

Allied health workers sometimes deliver group-based supports to multiple participants simultaneously. As a result, individual rights and privacy obligations become more complex to manage. Furthermore, funding arrangements for group sessions must be structured in accordance with NDIS price limits.

Consent processes must cover the group format specifically. In addition, workers must be vigilant that no participant’s information is inadvertently disclosed to others in the group.

Dual Obligations: NDIS Code and AHPRA Requirements

This is the most distinctive aspect of therapy worker obligations. Allied health workers registered with AHPRA carry dual compliance responsibilities that most other NDIS workers do not face.

AHPRA-Registered Professions Within the NDIS

The following allied health professions are regulated by AHPRA and therefore carry dual obligations within the NDIS context:

Occupational therapists
Physiotherapists
Speech pathologists (via Speech Pathology Australia’s standards)
Psychologists
Podiatrists
Osteopaths
Chiropractors
Optometrists
Dental practitioners
Pharmacists

Each of these professions has its own code of conduct, which AHPRA administers. Therefore, a compliance framework for an allied health NDIS provider must account for multiple professional codes simultaneously.

Where the Codes Align

Fortunately, there is significant alignment between the NDIS Code and AHPRA professional codes. Both require safe and competent practice, informed consent, respect for patient/participant autonomy, and confidentiality. Furthermore, both prohibit sexual misconduct in absolute terms.

As a result, a well-designed compliance system can address both sets of obligations through unified policies and training. However, the details differ in important ways that require specific attention.

Where the Codes Diverge

The NDIS Code places specific emphasis on participant choice and control that goes beyond typical health professional codes. Consequently, allied health workers must sometimes adapt their clinical approach to prioritise participant preferences over clinical best practice recommendations.

Moreover, AHPRA codes are profession-specific, while the NDIS Code applies uniformly across all support types. Therefore, an OT delivering both clinical therapy and daily living supports must navigate different standards depending on the activity being undertaken.

Managing Mandatory Reporting Under Both Systems

Allied health workers have mandatory reporting obligations under AHPRA that require them to report certain matters about colleagues. In addition, they have reporting obligations under the NDIS Commission framework. Furthermore, state and territory child protection and adult safeguarding laws add further layers.

Consequently, workers should have clear, documented guidance from their employer about which body to report to, in what order, and within what timeframe. A flowchart decision tool is highly effective for this purpose.

For detailed information on NDIS incident reporting requirements, review our NDIS reportable incidents guide.

Does NDIS Code of Conduct Training Apply to Allied Health Workers?

Yes. All NDIS workers — including allied health workers — must complete Code of Conduct training as part of their onboarding and at regular intervals thereafter. Moreover, employers must be able to demonstrate that training has occurred.

What Training Must Cover

Effective NDIS Code of Conduct training for allied health workers should include all seven obligations, with clinical examples relevant to therapy settings. Furthermore, it should address the interaction between NDIS obligations and AHPRA professional standards. In addition, the training must cover mandatory reporting procedures and complaint processes.

Frequency of Training

The NDIS Commission does not specify a mandatory frequency for refresher training. However, best practice suggests annual refresher training at a minimum. Moreover, training should be updated whenever the Code or supporting guidance changes. Consequently, providers should subscribe to NDIS Commission notifications to stay current.

See our dedicated resource on NDIS Code of Conduct training requirements for detailed guidance on training frameworks.

Common Compliance Gaps for Allied Health Workers

Several recurring compliance issues appear specifically in allied health NDIS practice. Understanding these gaps is the first step toward closing them.

The following documentation compliance areas are most commonly cited as deficient in allied health NDIS audits and complaints investigations:

Undocumented verbal consent for assessments, therapy, and information sharing
Progress notes that describe activities but do not link to participant goals
Billing records that do not reconcile with session notes or appointment logs
Incident reports that are incomplete or submitted outside required timeframes
Worker screening records that are outdated or not held on file
Training records with no evidence of Code of Conduct induction completion

Scope Creep Beyond Professional Registration

Some allied health workers gradually extend their practice into areas outside their professional scope. For example, an OT may begin providing informal counselling that crosses into psychology territory. As a result, both NDIS Code and AHPRA obligations may be breached simultaneously.

Inadequate Documentation of Participant Consent

Therapy workers often obtain verbal consent but fail to document it adequately. However, in the event of a complaint, undocumented consent may be treated as though no consent was given. Therefore, written consent records are essential for every clinical interaction.

Incorrect Billing Against NDIS Price Limits

Allied health NDIS billing is complex. In addition, price limits differ by registration group, support type, and geographic location. Consequently, errors in billing are common and can constitute both a Code breach and a NDIS fraud issue.

Our guide on NDIS billing software explains how automated tools reduce billing errors for allied health providers.

Failure to Maintain Current Professional Registration

AHPRA registration must be renewed annually. However, some workers continue delivering NDIS supports while their registration is lapsed or while conditions are attached. As a result, both the worker and their employer may be exposed to serious compliance risk.

Do Allied Health Workers Face Special Obligations Around Behaviour Support?

Psychologists and other allied health workers who provide behaviour support plans face additional obligations. The NDIS Commissioner has specific requirements for Behaviour Support Practitioners, including registration as a specialist practitioner. Moreover, behaviour support plans that authorise restrictive practices must comply with state and territory legislation as well as NDIS rules.

Therefore, allied health workers delivering behaviour support must ensure they hold the appropriate specialist registration with the NDIS Commission, in addition to their AHPRA registration. Furthermore, their organisation must have robust oversight processes for the review and implementation of behaviour support plans.

Review the NDIS Practice Standards guide for information on the specific standards that apply to behaviour support practitioners.

How to Build a Dual Compliance Framework

Allied health NDIS providers need compliance systems that address both the NDIS Code and AHPRA requirements systematically. The following structure provides a practical starting point.

Step 1: Map All Applicable Obligations

Create a register of every applicable code, standard, and regulation. This should include the NDIS Code of Conduct, the NDIS Practice Standards (if registered), the relevant AHPRA professional code for each profession employed, and applicable state legislation. Furthermore, the register should be reviewed at least annually.

Step 2: Develop Unified Policies

Draft policies that address NDIS and AHPRA requirements simultaneously wherever they align. In addition, create specific procedures for areas where the two frameworks diverge. Consequently, workers have clear guidance rather than competing instructions from different policy documents.

Step 3: Deliver Integrated Training

Training should cover both NDIS obligations and professional code requirements in a single, coherent program. Moreover, case studies should use clinical scenarios that are directly relevant to the allied health worker’s role. As a result, workers can apply the training immediately in their day-to-day practice.

Step 4: Implement Monitoring and Audit Systems

Regular internal audits of clinical documentation, billing records, and consent processes are essential. Furthermore, AHPRA registration currency should be verified for every worker on a regular basis. In addition, supervision structures should include explicit Code compliance discussions.

Our NDIS compliance checklist provides a ready-to-use audit tool for allied health providers.

How Inficurex Helps Allied Health NDIS Providers Stay Compliant

Managing dual compliance obligations is time-consuming and complex. Inficurex is purpose-built NDIS provider software that simplifies compliance for allied health organisations. Furthermore, it integrates documentation, billing, incident management, and compliance monitoring into a single platform. As a result, your team spends less time on administrative tasks and more time delivering therapy.

Inficurex supports accurate NDIS billing aligned with current price limits, automated compliance alerts, secure clinical documentation, and progress note templates tailored for allied health practice. Moreover, its audit trail features make it straightforward to demonstrate Code compliance during a Commission investigation or audit. Consequently, allied health providers can maintain confident compliance across both their NDIS and professional obligations.

In addition, Inficurex’s worker management tools help you track AHPRA registration currency, training completion, and supervision records in one place. Therefore, you always know your compliance status before a problem arises. Explore Inficurex for allied health providers today.

Allied health workers can also explore our resource on NDIS progress notes for clinical documentation best practices.

Frequently Asked Questions

Does the NDIS Code of Conduct apply to private practice allied health workers?

Yes. The NDIS Code of Conduct applies to all workers delivering supports to NDIS participants, regardless of whether they work for a registered provider or as a private practitioner. Moreover, unregistered providers must still comply with the Code.

Are allied health students on placement covered by the NDIS Code?

Yes. Allied health students delivering NDIS-funded supports during placement are considered workers for the purposes of the Code. Therefore, supervising organisations must ensure students receive Code induction and are supervised by a qualified practitioner.

What is the relationship between NDIS Practice Standards and the Code of Conduct for allied health providers?

The NDIS Practice Standards set service quality benchmarks for registered providers and are assessed during audits. The Code of Conduct sets behavioral expectations for all providers and workers. Furthermore, both are administered by the NDIS Commission. Allied health registered providers must comply with both simultaneously.

Do allied health workers need separate worker screening checks for the NDIS?

Yes. Allied health workers who provide NDIS supports must hold a valid NDIS Worker Screening Check. This is separate from state-based Working With Children Checks or other employment screening. Furthermore, the NDIS Worker Screening Check must be maintained and renewed.

How does the NDIS Code of Conduct apply to telehealth allied health services?

The Code applies to telehealth in exactly the same way as face-to-face services. Therefore, allied health workers must maintain the same standards of safety, privacy, consent, and professional conduct during telehealth sessions. In addition, billing for telehealth must comply with NDIS price guide requirements for remote service delivery.

Can allied health providers lose NDIS registration due to an AHPRA investigation?

Yes. An AHPRA investigation that results in suspension or cancellation of professional registration may also trigger a review of NDIS registration status. Moreover, the NDIS Commission may take independent action based on the same underlying conduct. As a result, allied health providers should treat AHPRA compliance as an integral part of their NDIS compliance strategy.

What records do allied health workers need to keep to demonstrate Code compliance?

Key records include signed consent forms, progress notes for every session, incident reports, training completion records, and supervision notes. Furthermore, billing records must reconcile with session documentation. Consequently, a clear document management system is essential for allied health NDIS providers.