Aged Care Quality Bulletin #33 – September 2021

Elderly couple both with glasses laughing

Commissioner’s message

Residential aged care providers across Australia deserve acknowledgement for the great job they have done in promoting and facilitating access to COVID-19 vaccination for their residents and staff. With the continuing rise in the proportion of the Australian population who are now vaccinated, there is good reason to look forward optimistically to a gradual easing of COVID restrictions and our collective adjustment to living in a COVID-normal world. I know that consideration is already being given – by providers, consumers, and family members, as well as health departments and the Commission – to the arrangements going forward that will provide the best possible life for aged care consumers. This needs to occur in the context of the enhanced protective measures now in place which have contributed to a significant reduction in the risk of serious illness or intensive care needs.

Included in this edition of the Bulletin is information about a public consultation process underway in relation to the implementation of the Australian Government’s decision to introduce cost recovery arrangements for the process undertaken by the Commission to assess applications from businesses seeking to be approved as aged care providers. The consultation period is open until 19 October 2021 and I encourage you to have your say. Learn more about this consultation and how to share your feedback via our website.

We also remind providers about the commencement of the next phase of the rollout of the Serious Incident Response Scheme (SIRS). From Friday 1 October, providers are required to report Priority 2 incidents (within 30 days) in addition to Priority 1 incidents (within 24 hours). To support providers with their SIRS reporting requirements, we’ve developed an online decision tool to help providers determine whether an incident is reportable and the timeframes in which it must be reported. Read more about Priority 2 incidents and access the online tool via the SIRS page of our website.

Public consultation open for introduction of approved provider application fee

Businesses seeking to provide aged care services subsidised by the Australian Government are required by law to be an ‘approved provider’, where approval is sought by submitting a written application which is assessed by the Commission.

The process of assessing the suitability of a business to provide aged care involves significant work, and the Government has determined that a cost recovery arrangement should be put in place for this process. The introduction of an application fee for provider approval applications is aimed at:

  • ensuring quality applicants at market entry level
  • increasing high-quality applications from businesses that will deliver high-quality aged care services 
  • improving the efficiency and responsiveness of the approval process
  • reducing the large number of applications received each year that are incomplete or don’t reflect an understanding of the legislated requirements that approved providers of aged care must meet.

The fee will apply to new applicants for approved provider status, and to existing approved providers who want to add to or change the service types for which they are approved. Additional costs will be payable by applicants who fail to provide all the evidence required in their initial application.

The Commission is now inviting feedback on the proposed arrangements and has launched a public consultation which closes on Tuesday 19 October 2021.

We have published a Cost Recovery Consultation Paper on our website which outlines the fees to be charged and the basis on which they have been devised.

We are particularly keen for feedback on whether and how we should approach a consideration of reducing or waiving fees for applicants who will deliver services in underserviced market areas or who target underserviced ‘special category’ consumers.

All relevant information is available on our Approved provider application fee consultation web page. To share your views, please complete the feedback form on our website.

When providing feedback, your identity and your organisation’s identity will remain confidential, and no individual or organisation will be identified in our consultation feedback summary to be published on our website at the end of the consultation period.

SIRS Priority 2 incidents now need to be reported

The commencement of the next phase of rollout of the Serious Incident Response Scheme (SIRS) signals another important step for the sector towards ensuring that aged care residents are safe and protected from harm.

Since 1 October, residential aged care providers are required to report Priority 2 incidents on the My Aged Care Provider Portal, in addition to Priority 1 reportable incidents (which have been reportable since 1 April). Priority 2 serious incidents in general are lower impact events or incidents, and are defined as reportable incidents that do not meet the criteria for a Priority 1 reportable incident.

If a reportable incident occurs, or is alleged or suspected to have happened, the provider must immediately take action to ensure the safety and well-being of those involved.

The priority of the incident determines when it must be reported to the Commission. Under the SIRS:

  • Priority 1 reportable incidents must be reported within 24 hours.
  • Priority 2 reportable incidents must be reported within 30 days of a provider becoming aware of the incident.

Providers must report incidents via the SIRS tile on the My Aged Care service provider portal. For more information about the portal, visit the Department of Health website.

New online decision support tool

To help providers determine what constitutes a Priority 1 or Priority 2 reportable incident, we have developed a decision support tool to complement the SIRS guidelines. The online tool prompts providers to answer questions when an incident has occurred which then helps them to resolve whether an incident is reportable and the timeframes in which it must be reported. The tool is available on our website.

Alis modules

A reminder to providers that a suite of learning modules about the 8 reportable incidents under the SIRS is available on Alis, our Aged Care Learning Information System. To access the new modules or to register for Alis, go to learning.agedcarequality.gov.au.

Do you have your behaviour support plans in place?

It is now a requirement for residential aged care providers to have a behaviour support plan in place for every resident who needs one. 

Behaviour support plans ensure that the rights, safety and well-being of senior Australians in care are at the centre of care planning and delivery.

An individual’s behaviour support plan forms part of their care and services plan, and is required for any care recipient:

  • who needs behaviour support
  • where the use of a restrictive practice has been assessed as necessary
  • where a restrictive practice is being used.

The requirements for behaviour support plans were introduced on 1 September 2021 to reduce restrictive practices in residential care and eliminate the inappropriate use of restrictive practices. These requirements are set out in the Quality of Care Principles 2014.

A behaviour support plan brings together important information about a resident’s background, preferences and behaviour. The plan also helps providers to identify when changes are required to meet an individual’s changing needs. It should include best practice, tailored support strategies that seek to optimise the individual’s quality of life, are aimed at reducing or ending the need for restrictive practices, and provide safeguards for the individual.

Dementia Support Australia was funded by the Department of Health to develop a wide range of resources on behaviour support plans and restrictive practices to help providers deliver best practice care. For more information, visit the Dementia Support Australia website.

Read more about behaviour support plans in the fact sheet available on our website.

Quality Indicator Program Manual Part B recently released

The National Aged Care Mandatory Quality Indicator Program (QI Program) expanded on 1 July 2021. Approved providers of residential aged care are now required to report quarterly on 5 quality indicators.

The Department of Health has recently published the National Aged Care Mandatory Quality Indicator Program Manual 2.0 – Part B on its website. This completes the three-part QI Program Manual:

  • Part A includes information about providers’ legislated reporting requirements, and the parameters of the data collection and reporting process referred to in the Accountability Principles 2014.
  • Part B includes guidance tools and resources to support providers’ use of QI Program data in the continuous improvement of their service.
  • Part C explains how providers are to report their QI Program data in the My Aged Care service provider portal.

All 3 parts of the manual can be found on the department’s QI Program web page, along with other guidance materials about the QI Program to support you to collect and submit data.

Data for the July–September 2021 quarter is due by 21 October. If you have any questions about data submission, you can contact the My Aged Care service provider and assessor helpline on 1800 836 799. The helpline is available from 8 am to 8 pm Monday to Friday and from 10 am to 2 pm Saturday.

If you have any questions about the expanded program quality indicators, you can contact the Commission’s QI Program team at: QIProgram@agedcarequality.gov.au. 

Commission’s expanded site audit program 2021–22

The Commission is aiming to significantly increase the number of re-accreditation site audits undertaken in 2021–22, and has set a target of delivering approximately 2,100 site audits of residential aged care services by the end of June 2022 – which is by far the largest number ever done in a single year. Achieving this objective will depend on a number of factors including the pace at which COVID risks and restrictions ease around the country, and particularly in New South Wales and Victoria.

To help us reach this ambitious target, we have engaged a panel of contractors to provide a supplementary quality assessor workforce. The contractor-suppliers have been selected through a rigorous procurement exercise involving an open tender process, and the Commission has now entered into a separate Deed of Services with KPMG, HDAA and RSM respectively.

Quality assessors engaged by these organisations must satisfy all requirements for registration by the Commission, including successful completion of the Commission’s Quality Assessor Training Program. When undertaking site audits, these quality assessors will operate seamlessly with other Commission staff, including complying with the mandatory vaccination requirements for all our field staff.

We continue to welcome feedback from providers and other stakeholders on our performance as a regulator. Please take up the opportunity available to all providers to let us know about your experiences of our site audits by completing the provider feedback survey.

Update on new worker screening register and code of conduct reforms

In response to the Final Report of the Royal Commission into Aged Care Quality and Safety, the Australian Government has announced its intention to implement a nationally consistent pre-employment screening process and a code of conduct across the aged care, veterans’ care and disability support sectors. Changes to the Aged Care Act 1997 and the Aged Care Quality and Safety Commission Act 2018 will be made to enable these reforms.

Worker screening register

The Government’s plan includes the establishment of a single register of workers in disability support, aged care and veterans’ care services across Australia, who have been either cleared or excluded during a nationally-consistent pre-employment screening process. This register, which will be accessible to providers, will support employment decisions across the care and support sector by enabling confirmation that individuals hold the necessary clearance to work in the relevant sector.

Code of conduct

It is also intended that a new code will be developed for aged care, disability support and veterans’ care workers and providers, based on the existing National Disability Insurance Scheme (NDIS) Code of Conduct. Breaches of the new code may result in a worker being prevented from being engaged in any part of the care and support sector. The Commission will be responsible for enforcing this code for aged care workers and providers, while the NDIS Quality and Safeguards Commission will continue its current enforcement role for NDIS workers and providers.

Stakeholder engagement and consultation on this initiative is expected to commence shortly and is likely to include publication of a consultation paper, online survey and targeted virtual forums providing an opportunity for input from a diverse range of interested parties from the aged care, veterans’ care and disability support sectors. Further information about this will be provided shortly by the Department of Health.

Do you understand your Prudential Standards responsibilities?

In 2020, the Commission undertook a sample audit of approved providers of residential aged care across Australia to assess their understanding of their refunding obligations and the Liquidity Standard and, more broadly, their responsibilities under the Prudential Standards.

The audit revealed that 10% of providers sampled were not compliant with the requirement to process refundable deposits within the 14-day refund period. The audit also found that both underpayments and overpayments of refundable deposit balances occurred. The number of overpayments – 35% of those sampled – would have a significant impact if replicated sector-wide.

The audit also found that half of the sample didn’t have a compliant refundable deposit register, while 10% of providers were unable to demonstrate that they maintained their minimum liquidity throughout the study period. Other findings of common non-compliance included the day of the refund not being included in the interest calculation, and refundable deposit registers missing key identifiable information.

At the end of the sample audit, all audited providers satisfactorily addressed identified areas of non-compliance. The final audit report is now available on our website.

The Prudential Standards sit alongside the Aged Care Quality Standards as requirements that residential aged care providers must meet, and provide additional protection for aged care recipients while ensuring accountability for providers. The Commission strongly recommends that provider boards and chief executive officers are familiar with the Prudential Standards as part of a robust approach to governance.

From the Chief Clinical Advisor

The Commission is continuing to work on raising providers’ awareness of the importance of strong antimicrobial stewardship (AMS) in residential aged care. Outlined below are 3 areas known to be problematic in residential aged care, which providers can consider in relation to their own services and processes. Medication Advisory Committees can also consider and address these issues. Providers should speak to their Quality Use of Medicines pharmacist about possible improvement activities and governance of AMS.

  • Allergies: Fundamental to the safe use of antibiotics is to have an accessible, accurate and up-to-date record of allergies for each resident. This is especially important where antibiotics may need to be prescribed and administered rapidly in the case of a severe infection, and where the person is unable to remember or communicate about their own allergies. Inadvertently giving an antibiotic when the person is allergic can have severe consequences, including anaphylaxis and death. If a person has no known allergies, then this should also be clearly recorded. Where possible, also record the nature of the allergy, for example, ‘penicillin – anaphylaxis’ or ‘amoxil – rash’. An audit of allergy recording is a simple way to ensure this safety issue is addressed and monitored.
  • End date: Where the end or ‘stop date’ is not recorded, there is a risk that antibiotics will be administered for longer than necessary, which can expose residents to unnecessary risk of harm and contribute to the development of antibiotic resistance. Antibiotic guidelines state the recommended duration for prescribing different antibiotics in each clinical setting. An audit of whether the end date is recorded on medication charts can be easily undertaken. Processes can then be put in place to ensure this occurs routinely.
  • Indication: Where an antibiotic is prescribed, it is important to record the reason it is being used, that is, the ‘indication’. This should be easily accessible to inform monitoring of the infection and clinical condition. It is also useful when transferring information to the person, their decision-makers, and/or to other clinicians in situations such as a transfer to a hospital or after-hours review. An audit of whether all antibiotic use has the indication clearly visible will assist providers with their AMS and oversight of antibiotic use.

New Alis module: ‘Engaging with consumers about their care’

In the last edition of the Quality Bulletin, we announced the new outbreak management planning modules available in Alis, our Aged Care Learning Information Solution. New content is continuing to be added, with a new module this month focusing on ‘Engaging with consumers about their care’.

When considering consumer engagement, it is important to recognise that some individuals may wish to be involved in all aspects of their service delivery, from care planning to organisational governance, while others may have more limited capacity or interest in engaging. Taking this into account, it is important that aged care providers understand that each individual’s background and history will influence how they experience the world, and their needs and preferences.

Our new Alis module will help leaders and managers working in aged care to reflect on how well they’re engaging with consumers about their care. It also suggests useful resources for further engagement.

To access the new module or to register for Alis, go to learning.agedcarequality.gov.au.

New and updated Commission resources

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Acknowledgement of Country

In the spirit of reconciliation, the Aged Care Quality and Safety Commission acknowledges the Traditional Custodians of Country throughout Australia and their connections to land, water and community. We pay our respect to their Elders, past, present and emerging and extend that respect to all Aboriginal and Torres Strait Islander peoples.