1. Purpose and scope

The purpose of this policy is to ensure that the interests, wellbeing, and goals of participants are always put first when Care Focus Support Services makes decisions or provides support coordination and related services.

This policy applies to:

• Timaima Naitau (Founder & Support Coordinator)
• Any contractors, support workers, or volunteers engaged by Care Focus Support Services
• Any other person acting on behalf of Care Focus Support Services

Care Focus Support Services is an unregistered provider. We are committed to upholding high ethical standards and aligning with the intent and spirit of relevant NDIS Practice Standards, even though we are not registered.

2. What is a conflict of interest?

A conflict of interest happens when a person’s personal, financial, or professional interests could influence, or be seen to influence, the decisions they make or the advice they give to a participant.

Personal conflicts

Personal conflicts of interest may arise when relationships or personal beliefs affect, or could be seen to affect, professional judgement. Examples include:

• Providing support to close friends, family members, or intimate partners
• Allowing personal views about disability, culture, religion, or lifestyle to affect service recommendations
• Accepting gifts, favours, or hospitality from participants or their families that may create a sense of obligation

Financial conflicts

Financial conflicts of interest may arise when a person or business could gain financially from a decision made about a participant. Examples include:

• Referring a participant to a service or business in which Care Focus Support Services or its staff have a financial interest
• Receiving commissions, referral fees, or other payments for recommending particular providers, products, or services
• Encouraging participants to purchase services or supports that are not necessary or not in their best interests to increase income

Professional conflicts

Professional conflicts of interest may arise when there are multiple roles or responsibilities that could affect impartiality. Examples include:

• Providing both support coordination and direct support services to the same participant where this may influence impartial advice
• Having another job or role with a service provider that may benefit from referrals from Care Focus Support Services
• Holding positions on boards, committees, or advocacy groups that may influence decisions about participant supports

3. Examples in disability support and support coordination

Conflicts of interest that are particularly relevant to disability support work and support coordination may include:

• Referring a participant only to services operated by friends, family, or business partners of Care Focus Support Services
• Failing to advise a participant of all reasonable service options because of a personal or financial connection to one provider
• Managing a participant’s NDIS plan while also delivering most of the services from the same business, reducing independence of advice
• Developing a close personal relationship with a participant that affects professional boundaries and decision-making
• Prioritising one participant’s needs over another’s because of a personal relationship or preference
• Using participant information to benefit another business or organisation without informed consent

4. Responsibilities to identify and disclose conflicts

Responsibilities of Care Focus Support Services

Care Focus Support Services is responsible for creating a culture where conflicts of interest are openly discussed, identified, recorded, and managed in a transparent way. This includes:

• Regularly considering whether any conflicts of interest exist in our relationships, referrals, or business activities
• Keeping records of any known conflicts of interest and how they are being managed
• Providing participants with clear information about any actual, potential, or perceived conflict of interest that affects them
• Avoiding arrangements that place staff in situations where their judgement may not be independent

Responsibilities of staff, contractors, and volunteers

Anyone working with or on behalf of Care Focus Support Services must:

• Act in the best interests of participants at all times
• Immediately tell the Founder & Support Coordinator (or their delegate) about any actual, potential, or perceived conflict of interest
• Not make decisions or give advice where a conflict of interest exists, unless a management plan has been agreed and documented
• Refuse any gifts, benefits, or hospitality that could reasonably be seen to influence their decisions or professional conduct
• Maintain clear professional boundaries with participants and their families

5. Managing and recording conflicts of interest

When a conflict of interest is identified, Care Focus Support Services will manage it in a way that protects the participant and supports fair, objective decision-making. Management actions may include one or more of the following:

• Disclosing the conflict to the participant in clear, plain language and checking their understanding
• Seeking the participant’s informed consent to continue with arrangements where appropriate
• Involving an independent person, advocate, or alternate provider to support decisions where needed
• Changing the roles or responsibilities of the person with the conflict so they are not involved in decisions
• Choosing not to provide a particular service or not to proceed with a referral where the conflict cannot be safely managed

All identified conflicts of interest and how they are handled will be recorded. Records may include:

• Details of the conflict and who is involved
• How the conflict was disclosed to the participant
• Any decisions made by the participant and any consent provided
• The agreed management plan and any changes to services or roles
• Review dates and outcomes of any follow-up actions

6. Participant rights and choice

Participants supported by Care Focus Support Services have the right to:

• Receive independent, unbiased information about support options as far as possible
• Be told about any actual, potential, or perceived conflict of interest that affects them
• Ask questions and request further information before making decisions
• Choose providers and supports that best meet their needs and goals, including choosing other providers instead of Care Focus Support Services
• Change providers at any time, subject to the terms of any current service agreement
• Have a trusted person, advocate, or representative involved in discussions about conflicts of interest if they wish
• Make a complaint if they feel a conflict of interest has not been properly managed

Participants will be reminded that they are in control of their own decisions and can seek independent advice or advocacy support at any time.

7. Complaints and concerns

If a participant, family member, carer, or other person is concerned that a conflict of interest has not been identified or managed properly, they are encouraged to raise this with Care Focus Support Services.

Concerns can be raised in person, by phone, or in writing using the contact details at the bottom of this page. We will treat all concerns seriously, respond in a timely manner, and, where appropriate, review decisions and arrangements to protect the participant’s rights and interests.

8. Review of this policy

This Conflict of Interest Policy will be reviewed regularly to ensure it remains current, practical, and effective. Reviews will consider feedback from participants, families, staff, and other stakeholders, as well as any changes in laws, guidelines, or good practice for disability support services.

At a minimum, this policy will be reviewed every two years, or earlier if:

• There are significant changes to the way services are delivered
• New risks or types of conflicts of interest are identified
• Concerns are raised about how conflicts of interest are being managed

Any updates to this policy will be communicated to participants and anyone working with or on behalf of Care Focus Support Services.