When is a restrictive practice reportable under SIRS?

Under SIRS, the inappropriate use of a restrictive practice is a reportable incident category. In a home or community setting, a use is not reportable only if all of these hold (Aged Care Rules 2025, s16-15): before the use, the care and services plan set out the circumstances (including behaviours of concern) and the manner (duration, frequency, intended outcome); it was used in those circumstances, in that manner, and in line with the plan; and the details were documented as soon as practicable afterwards. The behaviour support plan and consent rules (Part 9) apply to approved residential care homes. This category is reportable regardless of whether the person was physically harmed.

Is a PRN psychotropic medication a restrictive practice?

It can be. A psychotropic medication given to influence a person’s behaviour, rather than to treat a diagnosed condition, is a chemical restraint and a restrictive practice. Where a PRN psychotropic is used to manage behaviour outside the requirements that apply to it, its use can be an inappropriate use of a restrictive practice that is reportable under SIRS. In a home or community setting the s16-15 test above applies; in an approved residential care home the consent and behaviour support plan rules apply.

Restrictive Practices and SIRS: What You Need to Report | Teiro

Q: Do you have to report a restrictive practice even if no one was hurt?

Yes. The inappropriate use of a restrictive practice is reportable regardless of harm severity. If there is no Priority 1 trigger, such as injury or discomfort requiring medical or psychological treatment or grounds to report to police, it is still reported as Priority 2 within 30 calendar days. The absence of visible harm does not remove the obligation to report.

Restrictive practices and SIRS: what you need to report

Restrictive practices are the SIRS category most likely to be under-reported, because the reportable event is often a routine-looking PRN medication, not a dramatic incident. This guide explains when the use of a restrictive practice is reportable, and why harm is not the test.

This is guidance, not a determination or legal advice. Whether an incident is reportable under SIRS, and at what priority, is a judgement your organisation's nominated delegate must confirm. SIRS rules change: always verify current requirements against current ACQSC guidance and your own SIRS policy before you act. When you are genuinely unsure, the safer default we recommend is to report. The Commission says: “If you’re unsure whether an incident is criminal, it’s best to report it to the police”.

How the category is framed

Under SIRS, the inappropriate use of a restrictive practice is one of the eight reportable incident categories. A restrictive practice is any practice or intervention that has the effect of restricting the rights or freedom of movement of a person receiving care. It covers chemical restraint, physical restraint, mechanical restraint, environmental restraint, and seclusion.

Which test applies depends on the setting.

Home and community. A use of a restrictive practice is not reportable only if all three of these hold (Aged Care Rules 2025, s16-15):

Before the use, the care and services plan set out the circumstances (including behaviours of concern) and the manner (duration, frequency, intended outcome).
It was used in those circumstances, in that manner, and in line with the plan.
The details were documented as soon as practicable afterwards.

Approved residential care homes. The behaviour support plan and consent rules in Part 9 of the Rules apply. A use that does not meet them is an inappropriate use of a restrictive practice.

Reportable regardless of harm

This is the point providers get wrong most often. The inappropriate use of a restrictive practice is reportable regardless of whether the person was physically harmed. The absence of a visible injury does not remove the obligation to report.

It is still assessed for priority like other categories. If there is a Priority 1 trigger, such as injury or discomfort requiring medical or psychological treatment or reasonable grounds to report to police, it is Priority 1 and notified within 24 hours. If there is no Priority 1 trigger, it is still reportable, as Priority 2 within 30 calendar days. What does not happen is the incident dropping out of scope simply because no one was hurt.

The under-reporting risk: PRN psychotropics and restraint

The most commonly missed reportable restrictive practice is chemical restraint through PRN psychotropic medication. A psychotropic given to influence a person's behaviour, rather than to treat a diagnosed condition, is a chemical restraint. When it is used to settle or manage behaviour without the required consent, or outside an approved behaviour support plan, that use can be an inappropriate use of a restrictive practice that is reportable under SIRS.

Because a PRN dose looks like ordinary medication administration, it is easy for it to be charted and never flagged as a restrictive practice at all. The same blind spot applies to physical restraint used reactively in the moment, such as holding a resident to stop them leaving, when it is not authorised or planned.

A well-kept medication administration record does not answer the restrictive practice question on its own, but it is what makes the pattern visible in the first place: what a PRN dose was given for, and how often. See how Teiro records that context on every PRN entry in medication management.

Illustrative: residential PRN used without consent or a plan

A resident of an approved residential care home becomes agitated overnight and is given a PRN antipsychotic to settle them. The person has no behaviour support plan authorising it and the required consent is not in place. No injury results. This points toward a reportable inappropriate use of a restrictive practice, at Priority 2, even though no harm occurred.

Illustrative: authorised and consistent with the plan

In a residential care home, the same medication, used with valid consent and strictly in line with an approved behaviour support plan and its documented conditions, is not an inappropriate use. In a home setting, a use that meets all three s16-15 conditions is not reportable. It still has to be recorded and monitored as a restrictive practice, but the reportable trigger is the inappropriate use, not the use itself.

Check a specific incident in the decision tool Priority 1 vs Priority 2 Unreasonable use of force under SIRS Back to the SIRS guide

Primary source

This page is based on guidance published by the Aged Care Quality and Safety Commission (ACQSC) under the Aged Care Act 2024 and the Aged Care Rules 2025, in force from 1 November 2025.

Related SIRS categories and safeguards

Restrictive practices sit close to two other high-risk categories, and to the credentialing that keeps a behaviour support plan actually enforced.

Where an act of omission becomes neglect

Illustrative examples across the severity range.

Not sure this one is reportable? Decision tool

Answer a few questions to see the likely category and priority.

Strengthened Quality Standards 2025

How Standard 2 incident management ties back to reporting obligations.

Enforce behaviour support requirements at rostering

Require specific credentials per client and stop unqualified carers being assigned.

Structured incident reporting

Log the incident, confirm reportability, and record the outcome with a full audit trail.

The record already exists by the time the clock is running

Teiro captures the incident at the point of care, timestamps the moment your team became aware of it, surfaces the classification question to your reviewer with the facts already attached, tracks the deadline once a priority is assigned, and produces the record you need to lodge your SIRS notification. The decision about whether something is reportable, and at what priority, stays with your organisation's delegate. Teiro makes sure that decision gets made in time, by the right person, with the facts already in front of them.

Teiro does not determine reportability, and does not submit notifications to the ACQSC or the NDIS Commission on your behalf. It produces the record your delegate needs to make the call and lodge it.