Have your say on the proposed Single Aged Care Quality Framework across aged care from July 2018: As part of reforms to the aged care system, the government is developing an end-to-end market-based system with the sector, where they claim that competition and ultimately the consumer, drives quality.
The department is keen to consult with as many individuals and organisations with an interest in aged care as possible. These include:
- consumers, their families and carers
- key sector groups
- aged care organisations
- staff of aged care organisations, and health and disability services providers
- advocacy groups
Both consultations close on Friday 21 April 2017. Late submissions will not be accepted.
Minister Wyatt's media release (9 Mar 2017)
What is suggested sounds very appealing on the surface, but the number of standards are being reduced from 44 to 8. Instead of oversight, providers are expected to 'demonstrate' compliance. The difficulties on how to validate the accuracy of process based accreditation when regulation is to be reduced, is difficult to understand.
Specific requirements around dental care, sensory loss (eg, sight, hearing, etc), medication management, continence management and palliative care – among other areas of clinical care – have been stripped from the proposed Single Aged Care Quality Framework.
While there are some references to clinical care, quality of life and to outcomes, there are no plans to actually examine the way care is provided and to evaluate it in an ongoing manner. This will be no more effective than the current system. With the reduced regulation in order to appease the industry and reduce the burden, it will be even more ineffective.
How this is to be verified in a system that is reducing regulatory oversight and slashing red tape is not revealed. Aged Care reforms also include plans to privatise accreditation services, allowing providers to choose their own agency to accredit them, self-assessments, less frequent audits (eg, site audits reduced from once every three years to five years) and a reduction of ACFI reviews.
Unless the Quality Framework is squarely focused on the clinical outcomes of care recipients, then it is not measuring quality of care at all and will remain simply a tick-box exercise for aged care providers.
It worries us that these aspirational changes serve providers and do not adequately protect consumers from commercial exploitation.
- Current: 44 Accreditation Standards
- Proposed: 8 draft Accreditation Standards
Consultation 1: Draft Aged Care Quality Standards
The reforms include a Single Aged Care Quality Framework with a single set of aged care standards for all aged care services and claims to 'help consumers make choices about the care and services they need'.
However, by nature the frailty and vulnerability of aged care residents excludes the ability for many to make informed choices - particularly when there is so little useful information published by the Agency or Department on aged care homes. The elderly seek stability, known faces and a known environment. They are easily disoriented by change, rarely exercise 'choice' and are vulnerable to being sold snake oil.
- Consultation 1 - Hub link: Draft Aged Care Quality Standards
- Consultation 1 - Consultation paper: Draft Quality Standards Consultation Paper (MS Word) 410.3 kB (PDF 1.1mb)
- Consultation 1: Online survey
Consultation 2: Options for assessing performance against aged care quality standards
This consultation includes options for a streamlined approach for assessing provider performance against this single set of standards.
- Consultation 2 - Hub link: Options for assessing performance against aged care quality standards
- Consultation 2 - Options Paper: Options for Assessing Performance (MS Word) 821.2 kB (PDF) 813.5 kB
- Consultation 2: Online survey
Important: To improve accessibility, we have included the complete list of survey questions below for both consultations.
How to make a submission:
- Download and read the related Consultation or Option Papers (for both consultations, see above)
- Complete the Online Survey
- Click on 'Submit'
Consultation 1 survey questions: Draft Aged Care Quality Standards
After you have read the Draft Quality Standards Consultation Paper (MS Word) 410.3 kB (PDF 1.1mb), complete this online survey and supply specific feedback in the text boxes directly below each question.
Q: 1. What is your email address?
Q: 2. Are you answering on behalf of an organisation? If so, please provide your organisation's name.
Yes / No
Q: 3. Do you give consent for your submission to be published in whole or in part?
(Required) Yes / No
Q: 4. What role best describes you? Please select all that apply.
- Aged care consumer, including family and/or carer
- Aged care service provider
- Aged care worker/professional
- Aged care advocate
- Peak body - consumer
- Peak body - provider
- Peak body - professional
- Other - please specify below
Q: 5. Do you identify with any special needs groups, or, does your organisation provide support or services to any special needs groups? Please select all that apply.
- People from Aboriginal and/or Torres Strait Islander communities
- People from culturally and linguistically diverse (CALD) backgrounds
- People who live in rural or remote areas
- People who are financially or socially disadvantaged
- People who are veterans of the Australian Defence Force or an allied defence force including the spouse, widow or widower of a veteran
- People who are homeless, or at risk of becoming homeless
- People who are care leavers (which includes Forgotten Australians, Former Child Migrants and Stolen Generations)
- Parents separated from their children by forced adoption or removal
- People from lesbian, gay, bisexual, trans/transgender and intersex (LGBTI) communities.
Q: 6. Where do you live, or, where does your organisation operate? Please select all that apply.
NSW VIC QLD WA SA TAS ACT NT
Q: 7. What is your location, or, the location where your organisation operates. Please select all that apply.
- Metropolitan / Regional / Rural/Remote
Q: 8. If you are an aged care service provider, please select all the types of care your service delivers.
- Residential care
- Home care
- Commonwealth Home Support Programme services
- Transition care
- National Aboriginal and Torres Strait Islander Program services
- Multi-purpose services
- Innovative care services
- Short term restorative care services
Q: 9. If you are an aged care service provider, which option below best describes the size of your organisation?
- Small / Medium / Large / Very large
General questions about the draft standards
Please give us your views on the draft standards by answering the questions below. You will also have an opportunity to provide feedback on each standard in the next section.
Q: 10. Do the consumer outcomes in the draft standards reflect the matters that are most important to consumers?
- Yes, always / Yes, mostly / Yes, sometimes / No / Don't know
Why? Do you have any suggestions about how they could be improved?
Q: 11. Are the organisation statements and requirements in the draft standards achievable for providers?
- Yes, always / Yes, mostly / Yes, sometimes / No / Don't know
Why? Do you have any suggestions about how they could be improved?
Q: 12. Are the draft standards measurable?
- Yes, always / Yes, mostly / Yes, sometimes / No / Don't know
Why? Do you have any suggestions about how they could be improved?
Q: 13. Are there any gaps in the draft standards? If so, what are they?
- Yes / No
Q: 14. Is the wording and the intent of the draft standards clear?
- Yes, always / Yes, mostly / Yes, sometimes / No / Don't know
Why? Do you have any suggestions about how they could be improved?
Q: 15. Are any draft standards or requirements NOT relevant to the following services? If so, please provide details below.
- Residential care
- Home care
- Commonwealth Home Support Programme services
- Transition care
- National Aboriginal and Torres Strait Islander Program services
- Multi-purpose services
- Innovative care services
- Short term restorative care services
Specific suggestions about each draft standard
If you have any additional comments on how to improve any of the individual draft standards and requirements, please provide these in the relevant spaces below.
The 8 draft standards (replacing the current 44 accreditation standards) are supplied in one document for your convenience.
Q: 16. Do you have any specific suggestions in relation to draft Standard 1: Consumer dignity, autonomy and choice? If so, what are they?
Q: 17. Do you have any specific suggestions in relation to draft Standard 2: Ongoing assessment and planning with consumers? If so, what are they?
Q: 18. Do you have any specific suggestions in relation to draft Standard 3: Delivering personal care and/or clinical care? If so, what are they?
Q: 19. Do you have any specific suggestions in relation to draft Standard 4: Delivering lifestyle services and supports? If so, what are they?
Q: 20. Do you have any specific suggestions in relation to draft Standard 5: Service environment? If so, what are they?
Q: 21. Do you have any specific suggestions in relation to draft Standard 6: Feedback and complaints? If so, what are they?
Q: 22. Do you have any specific suggestions in relation to draft Standard 7: Human resources? If so, what are they?
Q: 23. Do you have any specific suggestions in relation to draft Standard 8: Organisational governance? If so, what are they?
Other Comments: Please provide details below about any other suggestions or comments you may have about the draft standards.
Q: 24. Do you have any other comments or suggestions about the draft standards?
Online survey: Draft Aged Care Quality Standards
Department of Health - Consultation Hub: Draft Aged Care Quality Standards
Consultation 2 survey questions: Options for assessing performance against aged care quality standards
After you have read the Options Paper (Options for Assessing Performance (MS Word) 821.2 kB (PDF) 813.5 kB), complete this online survey and supply specific feedback in the text boxes directly below each question.
Q: 1. What is your email address?
Q: 2. Are you answering on behalf of an organisation? If so, please provide your organisation's name.
Yes / No
Q: 3. Do you give consent for your submission to be published in whole or in part?
(Required) Yes / No
More detail about you
Please take a few moments to provide us with more information about who you are.
Q: 4. What role best describes you? Please select all that apply.
- Aged care consumer, including family and/or carer
- Aged care service provider
- Aged care worker/professional
- Aged care advocate
- Peak body - consumer
- Peak body - provider
- Peak body - professional
- Other - please specify below
Q: 5. Do you identify with any special needs groups, or, does your organisation provide support or services to any special needs groups? Please select all that apply.
- People from Aboriginal and/or Torres Strait Islander communities
- People from culturally and linguistically diverse (CALD) backgrounds
- People who live in rural or remote areas
- People who are financially or socially disadvantaged
- People who are veterans of the Australian Defence Force or an allied defence force including the spouse, widow or widower of a veteran
- People who are homeless, or at risk of becoming homeless
- People who are care leavers (which includes Forgotten Australians, Former Child Migrants and Stolen Generations)
- Parents separated from their children by forced adoption or removal
- People from lesbian, gay, bisexual, trans/transgender and intersex (LGBTI) communities.
Q: 6. Where do you live, or, where does your organisation operate? Please select all that apply.
NSW VIC QLD WA SA TAS ACT NT
Q: 7. What is your location, or, the location where your organisation operates. Please select all that apply.
- Metropolitan / Regional / Rural/Remote
Q: 8. If you are an aged care provider, please select all the types of care your service delivers.
- Residential care
- Home care
- Commonwealth Home Support Programme services
- Transition care
- National Aboriginal and Torres Strait Islander Program services
- Multi-purpose services
- Innovative care services
- Short term restorative care services
Q: 9. If you are an aged care service provider, which option below best describes the size of your organisation?
- Small / Medium / Large / Very large
Questions about how service provider performance is assessed against the aged care draft standards
Please share with us below your views about the current arrangements and any other comments or suggestions you would like to make about the reforms.
The Options Paper includes sections entitled "Your thoughts" which may help prompt your feedback to questions in this section of the online survey.
Q: 10. What are the features of the existing assessment and monitoring process that should be retained?
Options paper - Your thoughts: What are the strengths of the current aged care quality assessment arrangements?
Q: 11. What are the features of the existing assessment and monitoring process that need to be changed?
Options paper - Your thoughts: What aspects of the current quality assessment arrangements need to be improved?
What other issues need to be considered in the design of any new quality assessment arrangements?
Questions about the Options Proposed
Please give us your views on options by answering the questions below.
The Options Paper includes sections entitled "Your thoughts" which may help prompt your feedback to questions in this section of the online survey.
Q: 12. Which option do you prefer? Please give reasons.
- Option 1
- Option 1 with Option 3
- Option 2
- Option 2 with Option 3
- Other
Reasons for preferred option: Summary of the options:
Features common to all options: A single set of aged care standards applicable across all care types (except for those set out in Option 3).
- A wider range of methods for assessing performance against the aged care standards.
- Continued use of data and intelligence to inform the risk-based assessment.
- Greater consumer involvement in the assessment process.
- Capacity for the Quality Agency to recognise compliance with other similar quality standards.
- Better information available to the consumer about the outcomes of the assessment.
- Government retains the capacity to examine complaints and take compliance action where the organisation does not comply with any of its legislative/contractual responsibilities.
Table 1: Summary of key features of three options for aged care quality assessments
|
Options |
Key features of each option |
|
Option 1: Quality assessment process based on care setting, with different approaches for residential care and home/community care (based on status quo) |
|
|
Option 2: Single risk-based assessment process applicable to all aged care settings |
|
|
Option 3: Safety and quality declaration by organisations providing low-risk services readily available to the broader population (can be combined with Option 1 or 2) |
|
Options Paper - Your thoughts
In relation to the features proposed to be common to all options:
- Do you agree that the features common to all options should be part of aged care quality assessments?
- What are some of the different ways in which an organisation (and its services) could demonstrate its performance against the standards?
- How could consumers be more effectively involved in the assessment process?
- What information is most valuable to consumers?
- What are the critical elements of any assessment process?
- How information gained from a quality assessment can drive competition in the market and assist consumers to make choices
If Option 1 was adopted:
- What are the advantages and disadvantages of this option?
- Should any new assessment approaches be included in this option?
- How can this option best accommodate future changes in service delivery (for example, new models of service delivery)?
If Option 2 was adopted:
- What are the advantages and disadvantages of this option?
- To differentiate between organisations (and their services) to enable more targeted quality assessments, would it be sufficient to consider the following risks or should other matters also be taken into account:
- The nature of the services being delivered
- The level of responsibility the service has for the consumer’s health, safety and wellbeing
- The performance history of the organisation and its services
- The organisation’s compliance with any other relevant standards or quality frameworks?
- How can we best create a more risk-based approach to performance assessment?
- What support would organisations (particularly community/home care organisations) need to transition to this approach?
- Should organisations that provide transition care also be subject to this single quality assessment framework (noting that the quality of most of these organisations is regulated by state and territory governments)?
If Option 3 was adopted:
- What are the advantages and disadvantages of this option?
- What criteria should be used to determine whether an organisation should be subject to safety and quality declaration rather than assessment?
- What types of organisations should be eligible to use this arrangement?
- Is there an alternative approach that provides appropriate safeguards for consumers while minimising red tape for organisations that only deliver low-risk services?
Q: 13. Please provide details of any other options that we should consider.
Q: 14. Will your preferred option/s maintain appropriate safeguards for consumers? Please explain your answer.
Q: 15. Will your preferred option/s decrease the regulatory burden on aged care organisations? Please explain your answer.
Options paper - Your thoughts: The Department seeks your comments on the impacts of the various options.
Q: 16. Do you have any other comments or specific suggestions about the matters discussed in the Options Paper?
Online survey: Options for assessing performance against aged care quality standards
- Department of Health - Consultation Hub: Options for assessing performance against aged care quality standards