Aged Care Crisis are contributing to the public debate by publishing our submission to the Review of the Government's Aged Care Advocacy Service (September 2015) (below).

Our inquiries revealed that neither the submissions to this Review, nor the final report are to be made available to the public. We were not going to be given an opportunity to become more informed and to debate the issues, nor will we know whether they have taken any account of our submission.  We have subsequently learned that the findings of the Review were discussed at a meeting of invited stakeholders - something that not all those who responded were told about.

Background to our response

The Review was far removed from the sort of community focussed strategies which we believe aged care should employ and have been so lacking in government practices, particularly in aged care. If government genuinely wants the community to participate and assist it, then it should publish all documents on it's website and provide an opportunity for comment and discussion so that the community can develop its knowledge and understanding by listening to others and engaging.

If community input is valued, then the report and its conclusions should be made publicly available. A failure to do so shows a disregard for those who have made considerable efforts to participate. Community are entitled to know what the impact of their input has been and whether it has been seriously considered. A failure to do so fuels the widespread feeling of hopelessness and inability to influence events – leading to community disinterest and disengagement with the political progress.

ACC are opening the public debate about this advocacy service here. We invite everyone who knows anything about this service to tell us more about it by commenting or making a larger contribution.  Lets debate and decide what we would actually like advocacy to be.

The Review was contracted to Australian Healthcare Associates (AHA) who supplied an pdfoptions paper502.46 KB setting out the issues where they wanted feedback, and a proforma based on that to be filled out.  ACC filled that out but as the form did not allow us to make the arguments that we needed to make, we made a supplementary submission. 

We invite you to read our submission and then make a short comment, or if you prefer, make a longer contribution to the debate about advocacy setting out your ideas. In our submission, we argued that the current structure is based on outdated 20th century thinking that is not working. We have called for a 21st century solution.

  • The first part contains ACC's responses to the questions in the feedback form. 
  • The second part (Supplementary Submission) is a short summary and a link to our supplementary submission. 

Options Paper Feedback Form

The feedback form questions (below, along with our responses) did not provide a format within which we could set out and explain what we felt are important issues, so we completed the feedback form but also wrote a supplementary submission.

Feedback form questions and our responses:

2 Future Options

2.1 Definitions of advocacy

Discussion question:

2.1.1 Do these definitions accurately describe advocacy in the context of a national end-to-end aged care advocacy service focussed on individual and independent support?

Advocates in carrying out their roles of advocacy, identify problems and see the failures in care and services.  These outcomes and findings are a basis for system advocacy and should not be artificially separated.  For example, by working closely together, the roles of advocacy, complaints handling, oversight, data collection and advising, can all feed off each other and form an accurate assessment of the services being provided.  System advocacy follows.

Integration of all oversight and support activities would empower individual advocacy, create a strong basis for system advocacy and inform regulation.  It empowers consumers and by acting with them has the potential to create an effective customer and so counter the risk of market failure - a growing problem in all markets where customers are vulnerable or powerless.  A definition of advocacy should refer to its relationship with other oversight processes and its greater role in the community.

The fragmentation of services protecting the vulnerable in our community limits the efficacy of individual advocacy.   These services should be supporting each other at the coalface in each community. 

2.2 Development of a national framework

Discussion questions:

2.2.1 Would you agree that a National Framework would effectively support the delivery of an end-to-end aged care advocacy programme?

2.2.2 What other considerations should be given to developing a framework?

2.2.1    Communities and services differ widely in their attitudes and in the sort of advocacy they might require.  Local communities are more effective in developing and managing advocacy services.  A National framework would be counterproductive if it sought to enforce conformity.  A national entity on which local advocacy groups were represented that offered advice and supported local advocacy would be useful. 

2.2.2    ACC would support an integrated service, but the integration and cooperation should occur in the community with national and state groups supporting the face-to-face activities in the local community.  21st century thinking sees a bottom-up community operated representational structure rather than a top-down bureaucratised one as the most effective for community services.

2.3 Service delivery principles and priorities for an end‑to‑end aged care advocacy service model

Discussion questions:

2.3.1 Do these principles represent good practice for the programme?

2.3.2 Are there other principles or key priorities that are critical to the success of an end-to-end aged care advocacy service delivery model?

It is not clear to us what an end-to-end model is.  Aged care is a diverse activity carried out in diverse communities by diverse people.  Too much central structure and organisation inhibits local community empowerment, local engagement and innovative solutions.  Government and central advocacy groups would be most effective as mentors supporting and advising local services as they respond to local needs and develop management systems that meet their objectives.

Power imbalance: A close relationship between individuals and powerful credible organisations usually leads to the individual adopting the thinking, cultural attitudes and logic of the organisation. Too close a relationship with providers can seriously erode the capacity to criticise and advocate.  It has created serious issues in oversight bodies globally, particularly those run by governments and/or politicians that have a close relationship with providers.  Our assessment that this was happening in the complaints system was confirmed by the 2009 Walton Aged Care Complaints Scheme Review.  Accreditation bodies face a similar problem because of their close relationship with the industry. This was mentioned in their submission to the Productivity Commission.

The range of providers entering the CDC marketplace extends from community focused not-for-profit to large multinational corporations with a very strong focus on profitability.  Some of the views of these new impressive sounding providers will be markedly different to those of the community.  Typically they ridicule their critics and it is difficult to maintain alternative arguments.

Funding: Funding, whether from governments or from businesses, can be a strong impediment to advocacy when this challenges government policy or impacts on the interests of the business.  Nationally and internationally, funded organisations have often remained silent when issues involving government or providers need attention. The business of both individual and systemic advocacy has been left to less powerful and impoverished non-funded or donations funded organisations.

Proposal: ACC believes that advocacy would be best organised by structuring it within empowered community organisations that are examining and supporting all aspects of care.  They are less constrained by the source of funding or the views of providers.  This will give them the support that they need in order to advocate effectively.  Good but constructive relationships are built from a position of strength - being able to insist that community values drive services and not personal financial or other priorities.

2.4 Objectives and Service Scope

Discussion questions:

2.4.1 Are these objectives appropriate for an end-to-end aged care advocacy model?

2.4.2 Are there other objectives that should be included?

Objectives have to be matched against the resources and capacity.   These services might be more effective if they were to harness and capitalise on the resources and volunteers in local communities.  A local community organisation managing all aspects of aged care on the community’s behalf would be an ideal structure through which advocacy services could operate effectively.

2.5 Outcomes sought

Discussion questions:

2.5.1 Are there other outcomes that an end-to-end aged care advocacy service should aim to achieve?

2.5.2 Can these outcomes be effectively measured?

The outcomes listed seem to be appropriate.  Currently, there is no data that can effectively assess the performance of any part of the aged care system.  One of the prime functions of any review or restructuring of aged care should be the on-going, regular and independent on-site collection of the sort of data on which aged care assessments and policies can be based.  Advocates, if they worked closely with a community oversight body, would be contributing valuable information to the database.

We believe that the aged care processes protecting and supporting consumers should be restructured as local community organisations that would also be responsible for monitoring standards of care and the collection of data.  All oversight processes would contribute to and be informed by this data.  For consumers and advocates, the information would be local, which is what they would need and not national and company supplied as happens now.

2.6 Eligible client populations

Discussion question:

2.6.1 Are there any anticipated problems with how eligibility is defined above?

The state advocacy groups support advocacy across multiple sectors so providing integration within advocacy.  Integration with other oversight and data gathering services seems to be poor.

Disability services and services to other marginalised groups might also be better served by being organised in the way we have proposed in aged care.  Integration and cooperation between these services at a community level would be highly desirable. 

We feel that this integration is not something that should be structured centrally, but should grow from within the community.  State advocacy services would support and oversee the services provided through the community organisations. Eligible people would be less likely to fall through the cracks.

2.7 Service structure

Discussion questions:

2.7.1 Bearing in mind the trade-offs and benefits of each option in relation to efficiency, national consistency, access and flexibility to respond to local needs, which option is preferred or seen as achieving the most robust model?

2.7.2 In the preferred option, how can the trade-offs be minimised?

2.7.3 Are there other options to consider?

Option 1: is out of step with a growing body of thought. 

Option 3: is most in keeping with up to date ideas and with ACC’s views.   We believe that the management of all aged care services for the community would be best done through a local community controlled organisation supported by government agencies and mentors.

Costs can be minimised and all of the aged care needs of local communities can be met by creating integrated and co-operating local organisations.  Other sectors including disability services would benefit from a similar structural readjustment.  Integration and the sharing of expertise would have benefits.

2.8 Funding considerations

Discussion question:

2.8.1 What factors should be considered in developing a funding model for the advocacy programme?

Funds can gradually be diverted from current centralised delivery services. The costs of this will reduce as community organisations cooperate and form their own central coordinating body, which can take over some of this.  Government will always remain a partner in and a joint customer of the services provided to the community by commercial operators.  This proposed community restructuring is consistent with government policy for small government and for community partnerships.

Ensuring access and appropriateness for people from special needs groups

Discussion questions:

2.8.2 Are there other options to facilitate more effective access by special needs groups that should be considered?

2.8.3 Within special needs groups there are people who are more vulnerable than others.  It could be argued that the particularly vulnerable are less likely to seek assistance and more likely to require it.  What additional strategies could be put in place to identify those who are truly vulnerable?

Local community organisations organising and overseeing all age related activities in the community will be well placed to identify people and groups like this and ensure that they do not fall through the cracks.  They would be in a position to advocate on their behalf and divert funding to assist them.

2.9 Interface with other services

Discussion questions:

2.9.1 Are there any key strengths of the NDAP that could be considered in a future aged care advocacy model or conversely from aged care advocacy within the NDAP?

2.9.2 Are there synergies and improved interactions between the existing programmes that should be considered?

These would emerge if there were on the ground local cooperating activities in local communities.  Research has shown that well structured local communities can and will innovate and cooperate.  Other local communities will take up successful activities.  Central structures and government should assist, facilitate and support. 

A system of shared values and a less conflicted culture than exists at present will have to develop over time.  An empowered community working with providers would be well placed to address the cultural divide that afflicts the sector.  Policy should grow and be built on what communities need and want.  The lessons of the 20th century must be learnt and the mistakes not repeated.  There is not much evidence of this happening in aged care.  As a community we must move on.

Supplementary Submission:

As indicated, it was not possible to make the arguments we needed to make so we sent a supplementary submission.  We do not know if it will be accepted and considered.

 This supplementary submission:

  1. Sets out our concern about the nature and efficacy of this important service given its very low profile in a system that is not working.
  2. Outlines the many problems in the current aged care system and attributes these to obsolete 20th century thinking.
  3. Explains modern 21st century thinking about citizenship, community engagement and citizen participation in governments at all levels and particularly in the provision of social services. It lists current projects, and describes studies showing which strategies work and which fail. It gives examples.
  4. Is critical of the tokenistic and paternalistic community engagement in aged care, a relic of the 20th century.
  5. Examines the current advocacy programs and the extent to which all of the services supporting residents and overseeing services are fragmented and operate separately
  6. Urges government to move to a system like the community aged care hub suggested elsewhere on this site. It suggests that all of the aged care services including data collection, oversight, measurements of standards, accreditation monitoring, advocacy and community feedback should be provided through and under the control of local community organisations close to the real world of aged care.  Here they would be integrated and work together to meet local requirements. The current one size fits all model was inappropriate. The existing government initiated services would be important partners. They would continue to play an important role, educating, supervising and mentoring to make sure the aged care system works smoothly.

View: Aged Care Crisis pdfsupplementary submission368.42 KB


#1 Michael Wynne 2015-11-26 18:00
There is additional debate about this on Australian Ageing Agenda. See "Special report: Seniors’ support services face review" at The federal government is pushing for a central national advocacy service but the providers and the existing advocacy services are apposed to this. The issues are canvassed in this article.