NDIA Accountability Project

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Branch Manager Fraud and Compliance

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DOCUMENT 1

FOI 22/23-1311 Delivered by the National Disability Insurance Agency

Position Details

The NDIA welcomes and encourages applications from people with disability, Aboriginal and Torres Strait Islander peoples, and people with diverse cultural and linguistic backgrounds.

Attribute Value
Position Name Branch Manager Fraud and Compliance
APS Classification SES Band 1
Group Strategy Development and CRO
Branch Fraud and Compliance
Reports to DCEO Strategy Development and CRO
Location Canberra, ACT
Tenure Ongoing

Position Description

The Branch Manager Fraud and Compliance is a SES Band 1 position. It is accountable to plan, lead and deliver highly complex outcomes, projects and work programs that have strategic, political and operational significance to the National Disability Insurance Agency (NDIA).

The Branch Manager Fraud and Compliance is a Functional Leadership position within the NDIA and has defined independence to make decisions within their area of accountability. It will lead and contribute to the strategic planning of the NDIA’s objectives and will set strategic direction, develop long-term plans and implement operational strategies aimed at achieving the NDIA’s mission to ‘build a world-leading National Disability Insurance Scheme’.

The primary responsibilities of this position include:

  • ensuring fraud risk is managed and controlled effectively across the agency, as detailed within the PGPA and Commonwealth Fraud Control Guidelines
  • developing and implementing fraud and risk strategy and providing assurance that the Agency is meeting Government and legislative requirements through effective capability and capacity building
  • addressing current and emerging areas of fraud, Scheme integrity and non- compliance across the Scheme in collaboration with the NDIA Executive Leadership Team
  • developing a payment integrity strategy and response for the provider and participant pathways

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Relevant Duties

 ensuring compliance with the Commonwealth Fraud Control Framework 2014 through a range of internal fraud prevention, detection and response initiatives  maintaining strategic and operational partnerships with law enforcement and relevant intelligence agencies to support the Agency’s fraud control activities and to support across government approaches to criminal and security matters  leading the NDIS Fraud Taskforce and ensuring Government priorities and objectives are delivered.

The Branch Manager Fraud and Compliance position provides an important leadership role within the NDIA. It is responsible to provide the leadership, control, planning, resource management, performance management and decisions for the Team Leadership, Team Membership and assigned Contractors working within the Fraud and Compliance work area.

1. Leadership (Knowledge)

 Apply extensive and proven knowledge and experience in Commonwealth risk management, fraud control, investigation frameworks and their operational delivery.  Apply contemporary knowledge and experience in Commonwealth criminal investigations, intelligence approaches and security frameworks (PSPF).  Relevant and recommended qualifications that meet the Australian Government Investigation Standard (AGIS). For this role, a Diploma of Government Investigations is required.

2. Leadership (Accountability)

 Accountable for enterprise level risks, controls and programs of work that directly inform, influence and support the NDIA Corporate Plan aspirations and objectives and contribute to Scheme sustainability and confidence.  Accountable to provide strategic advice to the Agency’s Board and Executive Leadership Team regarding the adequacy of controls and integrity of processes, their application across the Agency and areas of potential exposure.  Responsible for providing an evidence-based view of fraud risk and control effectiveness through the annual program of work approved by the NDIA Board and Executive Leadership Team.

3. Diversity and Span

 Oversee all elements of fraud risk and control for the NDIA and NDIS for staff, participants, partners and providers.  Inform broader review and reform activities including Pathways Design, Enterprise risk, Control design, frontline management process design, data architecture and infrastructure.

Stakeholder Management

  • Exercise specific criminal investigation delegations defined within Commonwealth Fraud Control Guidelines, in addition to APS Human Resource and financial delegations.

  • Extensive high level stakeholder engagement with the Deputy Chief Executive Officer and Executive Leadership Team in relation to fraud, anti-corruption and security related risks, controls and activities, and to the CEO and Board on sensitive matters.

  • Build, sustain and manage collaborative relationships with NDIA teams to ensure control and assurance activities are imbedded and scalable in line with the Fraud Roadmap program.

  • Lead the inter-departmental NDIS Fraud Taskforce, a high profile Government priority critical to scheme integrity and sustainability and community confidence.

  • Regularly engage with the Department of Human Services, the Australian Federal Police and the broader law enforcement and Commonwealth community to facilitate delivery of objectives, ensure ongoing support and inform Commonwealth fraud strategy.

Job Context and Environment

  • Provide evidence based assurance to ELT and Board that fraud risk and loss are being managed effectively and that controls have been improved to mitigate risk.
  • Develop and report on financial loss and investment return of fraud and compliance activities.
  • Build Agency level fraud risk management capability through the delivery of:
    • the NDIA Fraud Control Plan
    • the NDIA Fraud Roadmap work program across 12 capabilities
    • NDIS Taskforce objectives
    • community and stakeholder confidence through proactive engagement
    • anti-corruption policy, procedures and control capability, supporting APS and NDIA conduct and standardise initiatives
    • the NDIA Compliance response framework.
  • Develop agency level capability in:
    • Investigations (Business As Usual and Task Force)
    • Intelligence
    • Data and Analytics in relation to fraud, staff integrity and compliance
    • Fraud Control Planning and Communications
    • Serious Non Compliance
    • Staff Integrity
    • Identity Management
    • Information Security

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6. Judgement and Independence

  • Apply extensive experience in working within complex legislative, policy and administrative settings.
  • Apply experience and judgement to decisions made, noting most will be largely untested due to the limited national and international precedent existing.
  • Utilise a high level of discretion and judgement in determining levels of staff fraud, corruption and conduct.
  • Apply highest levels of discretion, security and confidentiality to engage in discussions of serious and organised fraud matters of national security.

Remuneration

A Total Remuneration Package (TRP), commensurate with the responsibilities of the position, will be negotiated with the successful candidate. The TRP may comprise of:

  • Base salary
  • Superannuation
  • Executive vehicle allowance
  • Official parking at main place of work

Other entitlements (in addition to TRP) may include:

  • Airline lounge membership
  • Home office support
  • Provisions for leave and relevant allowances (e.g. travel) etc.
  • Relocation assistance (if relevant)
  • Salary Packaging

Security/Eligibility

This position requires (or the ability to obtain) a Negative Vetting Level 1 security clearance.

Branch Manager Compliance Program

Position Description

The NDIA welcomes and encourages applications from people with disability, Aboriginal and Torres Strait Islander peoples, and people with diverse cultural and linguistic backgrounds.

Attribute Value
Position Name Branch Manager Compliance Program
System Job Title NDIA SES1 Branch Manager
APS Classification SES Band 1
Group Chief Risk Officer
Division Chief Risk Officer
Branch Compliance Program
Reports to Chief Risk Officer
Location Canberra/Geelong/Melbourne/Sydney
Tenure Ongoing/Non-ongoing
Security Classification Negative Vetting Level 1

Position Purpose

About the NDIA

The National Disability Insurance Agency (NDIA) is an independent statutory agency that is responsible for implementing the National Disability Insurance Scheme (NDIS), which will support a better life for hundreds of thousands of Australians with a significant and permanent disability and their families and carers. The NDIA values a positive contemporary attitude to disability.

As a Federal Agency, we work within a legislative and regulatory environment. We adhere to the Australian Public Service Code of Conduct as set out in section 13 of the Public Service Act 1999.

Our work is driven by the Corporate Plan which provides strategic direction to achieve our purpose of making a difference so that people with disability can choose and achieve their goals.

The NDIA Values are:

  • We value people – We put participants at the heart of everything we do.
  • We grow together – We work together to deliver quality outcomes.

FOI 22/23-1311

• We aim higher – We are resilient and always have the courage to do better. • We take care – We own what we do and we do the right thing.

Our values reflect our passion and commitment to building a positive, participant-centred culture. The NDIA welcomes and encourages applications from people with disability, Aboriginal and Torres Strait Islander peoples, and people with diverse cultural and linguistic backgrounds. Where possible, the NDIA will make reasonable adjustments to enable individuals with disabilities to perform the essential functions of the role.

About the Role

The Branch Manager Compliance Program is a SES Band 1 position. It is accountable to plan, lead and deliver highly complex outcomes, projects and work programs that have strategic, political and operational significance to the National Disability Insurance Agency (NDIA).

The Branch Manager Compliance Program is a Functional Leadership position within the NDIA and has defined independence to make decisions within their area of accountability. It will lead and contribute to the strategic planning of the NDIA’s objectives and will set strategic direction, develop long-term plans and implement operational strategies aimed at achieving the NDIA’s mission to ‘build a world-leading National Disability Insurance Scheme’.

The primary responsibilities of this position include:

  • Developing and managing the Compliance Program to maintain the integrity of the National Disability Insurance Scheme outlays.
  • Providing the strategic and operational direction and leadership of the Agency’s compliance function to ensure payment integrity and facilitate a reduction of potential fraud and non-compliance to the Agency and the Scheme.
  • Managing the delivery of key enabling support including strategic and operational policy, ICT, Fraud Reporting Hotline/email, and workload management functions.
  • Managing data acquisition, privacy and data analytical processes and tools for the Agency’s fraud and compliance functions.
  • Analysis of risk to inform the development, planning, prioritisation and implementation of strategies to ensure payment compliance.
  • Ensuring policy, data, governance and quality development activities support the effective delivery of payment integrity outcomes in line with the Agency’s objectives.
  • Conducting tip-off operations to collect, analyse, triage and refer for action information from members of the public and Agency staff on potential non-compliance or fraud.
  • Developing and implementing continuous improvement strategies to improve productivity, capability, reduce duplication, minimise impact on participants and third parties (such as providers), and improve timeliness in compliance responses.
  • Supporting and enabling the implementation of Budget measures and other agency priorities.
  • Influencing and shaping high quality business outcomes by providing professional and ongoing advice to the NDIA strategic and functional leaders and their teams.

(NOTE: the key responsibilities of the role are based on current priorities and may change over time)

The Branch Manager Compliance Program position provides an important leadership role within the NDIA. It is responsible to provide the leadership, control, planning, resource management, performance management and decisions for the Team Leadership, Team Membership and assigned Contractors working within their work area.

Position Description for: Branch Manager Compliance Program (12/10/2021) 2

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Relevant Duties

Leadership (Knowledge)

  • Applying an extensive knowledge of the legislative requirements of the National Disability Insurance Scheme Act 2013 (the NDIS Act) and the NDIS rules and the Public Governance, Performance and Accountability Act 2013 (the PGPA Act) and the PGPA rules in addition to other key legislation and to the design and implementation of the NDIA’s compliance initiatives.
  • High-level of strategic understanding of the operational requirements, systems, processes and deliverables of the NDIA to manage and prevent non-compliance; providing expert advice and recommendations on compliance and payment integrity strategies that is regarded as an authoritative source to the Chief Risk Officer, Executive Leadership Team (ELT), the Board and NDIA strategic leaders.

Leadership (Accountability)

  • Accountable to establish, integrate and maintain best practice compliance practices across the NDIA; setting the direction, accountabilities, standards and expectations to provide a high-level of operational information, advice and recommendations on the performance of NDIA functions to the ELT, the Board and the Audit and Risk Committees.
  • Accountable to present compliance findings including:
    • NDIA’s strategic governance;
    • outcomes of the accountable authority in meeting their duties and responsibilities under the PGPA Act and other key legislative and regulatory requirements.
  • Accountable to develop and implement the compliance monitoring, assessment and reporting processes and tools that gather detailed information to assess, benchmark and provide detailed recommendations for management.
  • Accountable to take reasonable steps to verify and to resolve any discrepancies in the data, information and reports provided by the NDIA’s compliance/integrity processes, systems and tools.
  • Accountable for the functional leadership of the Compliance Program Branch, including the management responsibility for the allocated, human, financial and physical resources, performance management, conflict resolution, identification of capacity, capability and training requirements.

Diversity and Span

  • Working across the NDIA to schedule and conduct compliance and payment integrity activities.
  • Working collaboratively with the strategic and functional leadership of the NDIA to communicate and provide the clarity on the information, data, systems, documented processes and staff that are required to be available to undertake the compliance function.
  • Span of control is 4 direct reports, with a branch of approximately 90 FTE.

Stakeholder Management

  • Being the principal and authoritative source of advice related to the compliance function within the NDIA to a diverse range of stakeholders including the ELT, CEO, Board and the Audit and Risk Committees.
  • Building and maintaining a comprehensive communication network across the NDIA to engage, promote and explain the compliance framework/policies and its importance in protecting the integrity and sustainability of the Scheme.
  • Leading engagement with key external stakeholders; sharing and providing compliance insights and analysis to clarify and inform outcomes that will impact on the direction of the NDIA.
  • Communicating compliance findings that identify key variances and risks to the operational sustainability of the NDIA; recommending outcomes to achieve a sustainable scheme.

Job Context and Environment

  • Providing high-level advice and support to the NDIA on how the NDIA can best be develop and implement actions to enable the NDIA to perform their duties effectively, and in particular to allow the CEO, ELT and the Board to be satisfied that the NDIA is operationally effective and sustainable.
  • Leading and conduct reviews on the operational performance of the NDIA; identifying key risks, variances to performances and issues impacting on the operational effectiveness, sustainability of the NDIA; researching and recommending continuous improvement actions.
  • Providing specialist and technical advice to the CEO, ELT and the Board.

Judgement and Independence

  • Operating with a significant amount of independence across the NDIA to implement compliance strategies; identifying the key risks and issues and control deficiencies that have an adverse impact on operational effectiveness and efficiency of the NDIA; select the best course of action; developing recommendations to improve, correct and prevent the risk and issues and/or enhance the control environment.
  • Exercising a high level of judgement drawing from a significant understanding of the operational requirements of the NDIA; provide expert advice for the improvement and correction of functions, activities or tasks being performed by the NDIA.

Capabilities of the Role

The NDIA work within a capability framework aligned to the Australian Public Service (APS) Work Level Standards. The capabilities detailed below are specific to the SES Band 1 and SES Band 2 levels.

Facilitating Change

Encouraging others to implement better approaches to address problems and opportunities; leading the implementation and acceptance of change within the workplace.

Customer Orientation

Placing a high priority on the internal or external customer’s perspective when making decisions and taking action; implementing service practices that meet the customers’ and own organisation’s needs.

Building Organisational Talent

Establishing systems and processes to attract, develop, engage, and retain talented individuals; creating a work environment where people can realise their full potential, thus allowing the organisation to meet current and future business challenges.

Execution

Ensuring others contribute to organisation strategies by focusing them on the most critical priorities, measuring progress, and ensuring accountability against those metrics.

Coaching and Developing Others

Providing feedback, instruction, and development guidance to help others excel in their current or future job responsibilities; planning and supporting the development of individual skills and abilities.

Operational Decision Making

Securing and comparing information from multiple sources and uses this as the basis for identifying operational business issues; committing to an action after weighing alternative solutions against important decision criteria.

Influencing

Using effective involvement and persuasion strategies to gain acceptance of ideas and commitment to actions that support specific work outcomes.

Position Description for: Branch Manager Compliance Program (12/10/2021)

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Driving for Results

Setting high goals for personal and group accomplishment; using measurement methods to monitor progress toward goals; tenaciously working to meet or exceed goals while deriving satisfaction from that achievement and continuous improvement.

Positive Approach

Demonstrating a positive attitude in the face of difficult or challenging situations; providing an uplifting (yet realistic) outlook on what the future holds and the opportunities it might present.

Work Level Expectations

The NDIA work within the Australian Public Service (APS) Work Level Standards. This position is aligned to the duties of the SES Band 1 classification.

Role Specifications

The role is required to be performed in a work environment that has the following core characteristics and requirements:

  • Working in an open office environment (exposure to general workplace chatter)
  • Working from home on occasion
  • Working in a hot desk environment
  • Significant periods of sitting at a counter or desk
  • Operating a telephone
  • Computer/screen-based work
  • Ability to use computer/software applications including Microsoft Office and NDIA business applications such as NDIA’s client records management system (CRM)
  • Assistance animals may be in the work area

In addition to the above, the role requires:

  • Attendance at external locations offsite including participants’ homes (which may have multiple stories or be accessible only via uneven ground, stairs)
  • Performing high levels of phone usage and/or face to face work
  • Driving a vehicle to attend external locations which are not otherwise accessible by public transport
  • Driving a vehicle to attend external locations offsite which are not otherwise accessible by public transport and be over long distances, in all traffic and weather conditions, including the capacity to deal with minor vehicle problems (e.g., changing a tyre).
  • Mobility over uneven terrain such as unsealed roads, footpaths, steps and stairs in all weather conditions.

Security

The following essential checks/clearances are required to perform the role:

  • Working with Children Check
  • NDIS Worker Screening Check
  • Australian Government Security Vetting Agency (AGSVA) clearance - a vetting process undertaken before an individual may have access to classified information and resources. This is only applicable to some positions within the NDIA that require the occupant to have access to classified Australian Government information
  • Pre-Engagement Check - this is a mandatory pre-employment security screening process. All employees and contractors of NDIA must undertake a Pre-Engagement Check. This check is

Position Description for: Branch Manager Compliance Program (12/10/2021) 5

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Organisational Responsibilities

The occupant of this position will be responsible for the identification, management and mitigation of risks related to their business functions.

The occupant of this position is accountable to provide leadership in the implementation, promotion of and compliance with the Work Health and Safety Act (Commonwealth) 2011 within their work area; and in addition identify, evaluate and manage risk that ensures that team members and other persons within the work area:

  • take reasonable care for their own health and safety;
  • take reasonable care that their acts or omissions do not adversely affect the health and safety of other persons;
  • comply with reasonable instruction, policy or procedures given or notified by the NDIA relating to health or safety across the NDIA.