Guide 05 · policy and practice

What is the difference between an NDIS policy and evidence that the policy is working?

Last verified: 12 August 2026 · Applies to: small providers building or reviewing a policy and evidence system.

Short answer: A policy describes the intended control. Evidence shows what the organisation has actually done, when it did it, who owned the step and what happened next. A current policy can be useful and still not show implementation. A record can exist and still be incomplete or unrelated to the stated scope. A credible evidence set links the policy, the operating record, the owner, the date and the review or close-out action.

Think in three layers

Layer one: the rule or method. The policy describes the organisation's intended way of working: who receives a complaint, how an incident is escalated, how a worker is screened, or how a risk is reviewed. It should have an owner, version, approval or issue date, review date and scope.

Layer two: the operating record. The record shows a real event or recurring control: a register entry, induction record, supervision note, review action, complaint response or evidence of a decision. It should not be invented simply to make the folder look complete. A blank or “none occurred” entry can be legitimate when it is controlled and explained.

Layer three: the index and explanation. The index makes the link visible. It identifies the policy, the record, the owner, the date, the status, the privacy treatment and the reason the item belongs in the evidence set. Without that link, a reviewer may have to search a large folder and infer currency.

A simple example

Suppose the complaints policy says complaints are acknowledged, recorded, escalated where necessary, investigated, closed and reviewed for learning. The policy is only the first layer. A useful evidence set might contain a controlled complaints register with the right fields, a redacted example showing the workflow, an owner and review date, and a learning or improvement record where the matter led to a change.

If there have been no complaints in the period, do not manufacture one. Retain the controlled register, the review record and a short explanation of the “none recorded” position. If the register is informal, label it partial and identify the next action. The quality of the evidence comes from its truth and traceability, not from filling every row.

What to do this week

1. Choose one control: incident, complaint, risk, worker screening or evidence filing.
2. Find its policy: record the current version, owner, review date and the scope it covers. If there is no policy, write NONE rather than backdating one.
3. Find the operating record: choose one redacted example or controlled “none” review. Note what it does and does not show.
4. Build the link: give the policy and record stable IDs and add the owner, date, status, privacy note and next action to the evidence index.
5. Check the gap: ask whether the record actually shows the policy's steps. If not, write the missing field or practice question.

Common mistakes

• Changing the filename to “final” and assuming that this proves the procedure is in use.
• Using a training attendance sheet to prove that a worker can perform the whole control in practice.
• Linking a generic policy to an event that belongs to a different entity, site, support or timeframe.

Why the distinction matters

The distinction keeps the provider's responsibility visible. Clearharbour can draft or configure an artifact, organise client-supplied evidence and explain the gap. The provider must implement the control, keep truthful records, make decisions and submit accurate information. An auditor or regulator decides what is accepted in its own process.

This is also why a readiness score should describe the supplied sample. A red or amber result may reflect missing material, incomplete records or a scope limitation. It is not a statement that the organisation has no practice outside the sample, and a green result is not a promise about a later audit.

Related: the audit-documents guide and the registers guide. This guide is operational information, not legal advice; last verified 12 August 2026.