Being a disability service provider in Australia today means constantly having to adapt to new pressures. From the financial strain of reduced revenue to increasing regulatory scrutiny, organisations face a precarious balancing act of lowering costs while raising service levels.

To better understand how providers can address the many challenges they face – and how brokers can support them – we sat down with one of Australia’s leading governance and safeguarding specialists, Dr Alan Hough.

Founder of Purpose At Work – a company helping human services organisations to improve quality and safeguarding – and co-editor of the book Disability Practice: Safeguarding Quality Service Delivery with Professor Christine Bigby, Alan has spent years exploring how service providers can strengthen governance and safeguarding to meet the complex needs of recipients.

In a recent conversation with Ansvar, Alan shared his insights on the obstacles facing disability providers today, the common blind spots that can increase organisational risk, and why boards need to look beyond policies and paperwork to build safer, higher-quality services.

Less Funding, Higher Risk

For providers across the sector, the financial impact of NDIS changes resulting in participant funding cuts has been significant. According to Alan, that financial pressure now represents “a risk in its own right”.

While organisations may have fewer discretionary resources available, their legal, ethical and moral responsibilities remain exactly the same. The challenge is that budget strain can drive decisions that can unintentionally increase risk.

Cost-cutting measures such as reducing learning and development budgets or increasing supervision ratios can have a direct impact on the quality and safety of services.

Alan points to a recent Federal Court case as a notable example. Of the $1.8 million penalty imposed on a disability provider, more than $1.2 million related to inadequate staff training and failures to assess workforce competency.

Though many of these pressures sit outside providers’ control, the solution isn’t to lower expectations around quality. Instead, organisations need to be increasingly deliberate about how they manage and mitigate risk with the resources available.

A Balance Between Policy and Practice

As organisations seek practical ways to strengthen practice within ever-tighter budgets, Alan sees one common mistake: placing too much emphasis on policies and procedures, and not enough on how they’re implemented in practice.

Of course, policies are an essential part of good governance. They’re critical for setting expectations and providing a clear framework for decision-making. But policy alone doesn’t reduce organisational risk.

Alan points out that the NDIS Commission and the courts are far more concerned with a policy’s implementation than its presentation. It’s what happens every day, on the front line of the organisation, that truly determines the success of governance and risk management.

A policy can describe how services should be delivered, but it can’t guarantee that staff have the capability, support and confidence to consistently put it into practice.

“We often underestimate the challenge in moving from good intentions to good practice,” Alan says. For providers, closing that gap between intention and implementation is where governance goes beyond compliance and starts reducing risk in ways that actually matter. 

“The NDIS Commission and the courts aren’t that concerned about whether you have a nice-looking set of policies and procedures in place. They’re concerned about whether those policies and procedures are appropriate and if they’re implemented in practice.” 

Alan Hough, Founder, Purpose At Work 

Turning Good Governance Into Everyday Practice

If policies provide the framework for clinical governance, practical risk management is about making sure that framework translates into safe, consistent support.

For disability service providers, this practice-based approach can be applied across four key areas.

1. Start with people, not compliance

According to Alan, effective risk management begins by putting the compliance checklist aside and understanding the people you support.

Every participant brings different needs, circumstances and levels of risk. While some risks are common across particular cohorts, others are unique to an individual’s health or personal situation. Organisations need to understand both the broad risks associated with the services they provide and the specific risks facing each participant.

As Alan puts it, providers need to consider “not just the ordinary risks”, but also those people whose circumstances place them at heightened risk. “You need to focus on both the general and the particular.”

2. Focus on the “work as done”

Understanding risk is the first step. The next is understanding whether the support being proposed is the support that’s actually being delivered. Alan describes this as the difference between “work as imagined” and “work as done.”

Work as imagined reflects the organisation’s documented policies and procedures. Work as done reflects the reality of day-to-day practice.

The distinction is key because governance can easily become disconnected from the frontline. Leaders may assume policies are being followed consistently, while staff are adapting processes to meet the realities of everyday service delivery.

Good governance means continually testing whether the practice reflects the intention – and not simply assuming it does.

3. Zoom in on micro-processes

Something we see time and again in disability services is that serious incidents rarely result from a single mistake, but rather a series of seemingly minor failures.

Referred to by Alan as micro-processes, these might be errors such as failing to update a risk assessment or share important information between teams. Individually, they may appear relatively insignificant. Together, they can create the conditions for harm.

“Harm results not from intention, but from organisations failing to think through the small steps that connect one part of a process to the next.”

Alan Hough, Founder, Purpose At Work

4. Step outside the boardroom

The focus on practice applies just as much to boards as it does to frontline teams. Directors can’t rely solely on board papers or performance reports to understand whether governance is working. They need to see how services are actually being delivered.

That means spending time where services are provided, speaking with staff and participants where appropriate, and drawing on multiple sources of information, not just reports from senior leadership.

By combining operational data with firsthand observations and frontline feedback, boards gain a more accurate picture of organisational performance and are better equipped to identify risks before they become bigger problems.

The Value of a Specialist Risk Partner

Just as boards benefit from multiple sources of information, organisations can also benefit from external perspectives. And this is where an insurer with sector specialisation can make a significant difference.

Speaking about disability insurance specialists like Ansvar, Alan highlights how an experienced partner can add valuable insight that providers may not have access to internally, particularly around risk management.

“It’s been very pleasing to see the way Ansvar has engaged in discussions about important risks in disability.” 

Alan Hough, Founder, Purpose At Work

He also recommends providers maintain an ongoing relationship with their broker rather than treating insurance as an annual transaction. Regular conversations help brokers build a deeper understanding of a client’s risk profile while giving the organisation access to broader trends and emerging risks across the sector.

A Hopeful Outlook for a Vital Sector

Despite the significant challenges facing the disability sector, Alan remains optimistic about its future. He believes there is a growing recognition of the importance of evidence-based practice, stronger clinical governance, and continuous improvement across the industry.

While funding pressures and regulatory demands are unlikely to ease in the near future, they also reinforce the importance of practical risk management strategies. And as Alan’s insights demonstrate, this isn’t something that’s built through policies alone.

In an industry under pressure, reducing risk comes from understanding the people being supported, embedding safe practices into everyday work, and continually testing whether services are delivering the outcomes they’re meant to achieve.

If you’re an insurance broker with disability sector clients, get in touch with your local Ansvar contact to discuss how we can help.

About Alan Hough 

Alan Hough, PhD, GMAICD, AICGG, is one of Australia’s leading specialists in quality and safeguarding, and organisational governance.

As well as founding Purpose At Work – a company supporting human service organisations to improve quality and safeguarding – Alan is the co-editor, with Professor Christine Bigby, of Disability Practice: Safeguarding Quality Service Delivery, a key resource for practitioners in the field of disability practice (available as a free download here).

Alan holds the honorary position of Adjunct Professor at the Living with Disability Research Centre at La Trobe University and is the Lead Editor of the academic journal Research and Practice in Intellectual and Developmental Disabilities.

Alan is based in Canberra.

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