Ivy Psychology
Interim vs Comprehensive Behaviour Support Plans: A Practical Comparison
The difference between an interim and a comprehensive behaviour support plan, covering the timeframes, what each contains, why the interim comes first, and what happens between them.
An interim behaviour support plan is a short-term safety document developed within one month of engagement, before the full assessment is finished. A comprehensive behaviour support plan is the full plan, developed within six months of engagement and built on a completed functional behaviour assessment.
Both are required under section 19 of the NDIS (Restrictive Practices and Behaviour Support) Rules 2018 where regulated restrictive practices are involved. The distinction is not a formality, because the two documents do genuinely different jobs.
Side by side
Interim behaviour support plan
- Due within one month of engagement with the specialist behaviour support provider
- Based on early information: initial interviews, existing reports, incident records, and observation
- Purpose is immediate safeguarding while assessment continues
- Identifies any regulated restrictive practices in use, with strategies to keep them as limited as possible
- Short and directive, so support workers and family can act on it straight away
- Must be lodged with the NDIS Commission where it contains regulated restrictive practices
Comprehensive behaviour support plan
- Due within six months of engagement
- Built on a completed functional behaviour assessment
- Explains the function of each behaviour of concern, meaning what it is communicating and what maintains it
- Sets out proactive strategies, skill development, environmental change, and response strategies
- Includes a reduction and elimination plan for any regulated restrictive practices
- Includes implementation responsibilities, monitoring, data collection and review arrangements
Why the interim comes first
A good functional behaviour assessment takes time. It involves interviews with the people who know the person, direct observation across settings, data collection on the behaviours of concern, review of prior reports, and analysis of what the data shows.
Meanwhile, people need to know what to do on Monday. If a participant is being physically restrained during transitions, or a pantry is being locked, that cannot wait six months for a formulation. The interim plan exists so safety and safeguarding start immediately, and so any restrictive practice already occurring is documented, authorised and constrained.
When the clock starts
Engagement generally means the date of the service agreement, or a date specified in it, rather than the first appointment. Two consequences follow. Delays in getting started eat into the one-month window rather than extending it, and if the practitioner changes within the same organisation, the original engagement date still applies.
New to behaviour support?
Our step-by-step guide covers what happens from referral through to the plan being written.
Read the guide →What happens between the two
The gap between the interim and the comprehensive plan is where most of the actual work sits, and most of it is not face to face.
- Data collection on the behaviours of concern by the people around the person
- Analysis of that data for patterns, triggers and function
- Direct observation in the settings where the behaviour happens: home, school, day program, community
- Interviews with family, support workers and other providers
- Review of clinical documents, assessments and incident reports
- Implementation training for the people delivering the interim strategies
- Writing the plan itself
If the interim strategies are working, that is useful evidence, not a reason to stop. If they are not, the comprehensive plan is where that gets corrected on the basis of data rather than impression.
Moving from interim to comprehensive
Where an interim plan already exists, a practitioner can move toward the comprehensive plan provided the interim plan is current, is actively reducing risk, has been lodged with the Commission, identifies all regulated restrictive practices in use, has an accurate schedule of those practices, and has valid authorisations.
If any of that is missing, the interim plan needs fixing first. Building a comprehensive plan on top of an inaccurate schedule of restrictive practices creates a compliance problem for everyone involved, including the implementing providers.
If a plan does not contain restrictive practices
The one-month and six-month timeframes apply specifically to plans containing regulated restrictive practices. Where no restrictive practices are involved, the NDIS Commission's position is that these timeframes should still be used as part of providing safe, quality services. We treat them as the standard either way.
Common misunderstandings
- An interim plan is not a draft of the comprehensive plan; it is a different document with a different purpose
- An interim plan is not optional where restrictive practices are in use
- A comprehensive plan is not final. It is reviewed and updated as data comes in and circumstances change
- Six months is a maximum, not a target. Where the assessment is complete sooner, the plan should be written sooner
Where we work
In summary
The interim plan is fast and protective, due within a month of engagement. The comprehensive plan is thorough and explanatory, due within six months and built on a completed functional behaviour assessment. The months between them are spent on assessment, data and implementation, which is the part that determines whether the comprehensive plan is worth anything.
Questions about your plan?
If you are unsure which plan you have or what should happen next, get in touch and we will talk it through.
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