Aged Care Quality Bulletin #34 – October 2021 | Aged Care Quality and Safety Commission

Four elderly people sitting on a couch laughing

Commissioner’s message

As the proportion of Australians who are fully vaccinated continues to rise, we are all beginning to adjust to living and working in a COVID-normal world. For providers of residential aged care services, this includes ensuring that arrangements are in place to enable safe access for family members and others seeking to visit residents onsite and/or take them on trips away from the facility.

National Cabinet recently agreed on a plan proposed by the Australian Health Protection Principal Committee (AHPPC) to re-open aged care facilities across Australia to visitors. This is an acknowledgement of the many benefits that visitors have for aged care residents.

I urge you to consider how you will re-adjust the visitation arrangements in your residential service(s) in line with the AHPPC’s recommendations to address residents’ and families’ needs and preferences to spend time together in person.

Update on our approved provider application fee public consultation

As outlined in the last edition of the Quality Bulletin, the Commission recently held a public consultation on the proposed introduction of a fee for applicants seeking to become approved providers of aged care services.

The proposed fee will apply to new applicants for approved provider status, and to existing providers seeking approval to provide additional or different types of services.

Our public consultation closed on 19 October, and we are currently reviewing the feedback received (with a de-identified summary to be published shortly on our website).

This feedback is being used to inform further advice to Government on the structure of the fees, and the principles for any fee waivers. Detailed information about all fees payable will be included in a Cost Recovery Implementation Statement which will be published on our website prior to the fee commencing during November 2021.

We will provide updates on the progress of the fee introduction on our Facebook, LinkedIn and Twitter channels.

From Dr Melanie Wroth, Chief Clinical Advisor

Common questions about restrictive practices

The Commission is working closely with providers to foster an understanding of the new requirements relating to any use of restrictive practices in residential aged care settings.

We’ve been responding to questions from providers about what the new requirements mean for frontline staff and for supporting senior Australians in their care.

In this edition of the Quality Bulletin, we address 3 common questions we’ve been receiving.

Are memory support units an environmental restraint?

Defining what is a restrictive practice depends on the primary purpose of the intervention and how it affects the resident.

The Quality of Care Principles (the Principles) define environmental restraint as a practice or intervention that restricts, or involves restricting, a resident’s free access to all parts of their environment (including items and activities) for the primary purpose of influencing the resident’s behaviour.

For example, if a resident resides in a secure memory support unit because they have dementia, they like to walk around, and the location of the facility combined with their lack of road awareness puts them at serious risk of being hit by a car if they go outside, this is considered a restrictive practice. In this instance, providers must follow all the steps outlined in the Principles.

If a bed-bound resident is in a memory support unit because there is no suitable alternative for their care, this is not a form of restrictive practice as the locked unit is not restricting their free movement.

For more details, read about Donald and Geoffrey in our restrictive practices scenarios.

How often do behaviour support plans need to be reviewed?

Behaviour support plans are now mandatory for all residents who require, or may require, the use of restrictive practices as part of their care.

The Principles state that behaviour support plans must be reviewed regularly and updated as soon as practicable when a resident’s circumstances change.

The timeframes for review will be informed by the ongoing monitoring of the effects of behaviour support strategies including restrictive practices.

For example, if the strategies are not effectively addressing the behaviour, or there are negative impacts on the resident, this would flag the need for review.

Rapidly changing behaviour or distress associated with the use of restrictive practices indicate the need for more frequent reviews.

Even when strategies are effective and the resident’s wellbeing and quality of life are good, regular reviews are still required.

A review needs to include whether the restrictive practice remains necessary, or if a less restrictive form can be utilised.

For more information, read our behaviour support plan fact sheet.

Which requirements apply when a restrictive practice is requested by a resident?

The requirements outlined in the Principles continue to apply when a resident or their representative requests an intervention that may be a restrictive practice.

It is important that providers have clear processes in place for responding to these requests. This includes working closely with the resident or their representative to understand the reason for their request.

Just because an intervention is requested for ‘safety’ reasons does not exclude it from the definition of a restrictive practice. The risk that the intervention is seeking to address must be defined, and any risks posed by the intervention should also be identified.

Even for non-chemical restraints, an approved health practitioner with day-to-day knowledge of the resident (for example, a general practitioner or a nurse) still needs to assess whether the practice is necessary.

The alternatives, benefits and risks must be discussed with the resident or their substitute decision maker, so that they can consider the pros and cons of these options. Their informed consent must be obtained and documented.

Providers must ensure a behaviour support plan is in place and that it is reviewed regularly if restrictive practices are applied.

Merle in our restrictive practices scenarios is an example of when this type of request has been made.

To Dip or Not To Dip pilot project and materials

The Commission is continuing to develop materials and resources to support the implementation of a To Dip Or Not To Dip pilot at a small number of residential aged care services in Queensland and Victoria.

This pilot project introduces a clinical pathway to guide diagnosis and treatment of urinary tract infections (UTIs) among residents. The aim of this pathway is to improve the quality of care for older people living in residential services with suspected UTIs, and to reduce unnecessary prescribing of antibiotics.

To Dip or Not To Dip was a project first implemented in England’s aged care homes that demonstrated how antibiotic use may be safely reduced by changing the way that UTIs are diagnosed, particularly regarding the decision about whether or not to conduct a urine dipstick test. The key issue here is that bacteria can be present in a person’s urine without causing that individual to feel unwell (asymptomatic bacteriuria), and screening and treatment of bacteriuria in older people in the absence of symptoms or signs is not recommended.

Learn more about this campaign by watching the To Dip Or Not To Dip video, and visit our website for other material about antimicrobial stewardship for providers, clinicians and consumers.

Our latest ‘Sector performance report’ is available

The Commission has released the Quarter 4 Sector performance report, for the April–June 2021 period.

This report provides a comprehensive overview of the performance of the aged care sector. It includes data and relevant information about provider approvals, complaints, accreditation, and compliance against the Aged Care Quality Standards. It also includes information about regulatory action the Commission took in Quarter 4 – and this is the first sector performance report with data about incident management compliance notices.

Our sector performance reports are a valuable source of information for aged care providers and consumers. They can be used by approved providers to help identify where there are challenges and opportunities to enhance consumer care outcomes. Current and prospective consumers and their families can draw on information in the reports to have a conversation with a particular provider about their performance. For example, they could ask a provider questions about whether they have received complaints from consumers and how they have been addressed, and whether they are currently compliant with the Aged Care Quality Standards.

If you have any questions, comments or feedback about these quarterly reports, please contact the Sector Performance Report team at cscr@agedcarequality.gov.au

Reminder – SIRS Priority 2 incidents are now also reportable

The Serious Incident Response Scheme (SIRS) is in full effect, with both Priority 1 and Priority 2 incidents now reportable. There are 8 types of reportable incidents under the SIRS. Since 1 April 2021, residential aged care service providers have been required to report Priority 1 incidents to the Commission within 24 hours of becoming aware of the incident. These are reportable incidents:

that have caused or could reasonably have been expected to cause a consumer physical or psychological injury or discomfort requiring medical or psychological treatment to resolve, or
where there are reasonable grounds to contact the police, or
where there is the unexpected death of a consumer or a consumer’s unexplained absence from the service.

All reportable incidents involving instances of unexplained absence from care, or unexpected death of a consumer, or where there are reasonable grounds to report the incident to the police are always to be regarded as Priority 1 reportable incidents. With respect to ‘reasonable grounds to report the incident to the police’, this includes (but can extend beyond) an incident involving unlawful sexual contact.

Since 1 October, providers must report Priority 2 incidents to the Commission within 30 days of becoming aware of them. Priority 2 reportable incidents are those that do not meet the criteria for a Priority 1 reportable incident.

To help providers determine whether incidents are reportable, and what constitutes a Priority 1 or Priority 2 reportable incident, a decision support tool is available. The online tool prompts providers to answer questions when an incident has occurred, to help them to determine whether an incident is reportable and the timeframes in which it must be reported.

The decision support tool has been updated to clarify the requirements for providers to report incidents relating to unlawful sexual contact or inappropriate sexual conduct to the police. The need to report these kinds of incidents to the police means that they should automatically be considered as Priority 1 incidents and reported to the Commission within 24 hours. The amendments provide additional information to clarify what constitutes reasonable grounds. Similar updates will be incorporated into the decision support tool for other types of reportable incidents.

For more information and resources, visit the SIRS page on our website.

Free Alis licence period extended to 1 July 2022

The Aged Care Learning Information Solution (Alis) complements the Commission’s delivery of face-to-face and virtual education programs. It also ensures that aged care staff can access our educational information anywhere and at any time.

The Alis platform contains a range of online learning modules, including ones focusing on the Aged Care Quality Standards, the Serious Incident Response Scheme, consumer engagement, outbreak management and clinical governance. New modules are added to the platform regularly.

To assist you with accessing these interactive learning modules, all Commonwealth-funded aged care service providers can access 4 free Alis registrations. This free access period has been further extended until 1 July 2022. You can also purchase additional Alis registrations to support your staff’s ongoing professional development.

If you have not yet registered for Alis, we encourage you to do so now. To register, go to learning.agedcarequality.gov.au or email education@agedcarequality.gov.au

To assist the Commission with progressing enhancements to the Alis platform, we will soon be conducting a survey to collect feedback from the sector. Further information will be provided to registered users by mid-November.

Our joint webinar series with the Pharmaceutical Society of Australia

The Commission and the Pharmaceutical Society of Australia (PSA) are jointly delivering a four-part webinar series over the next few months. The first webinar was held on 13 October and focused on the role of pharmacists in residential aged care, the Commission’s role and functions, and initiatives in the Government’s aged care reform package that relate to medication and respond to issues raised in the Royal Commission into Aged Care Quality and Safety.

The series will continue with webinars scheduled for 10 November, 8 December and 9 February 2022.

The topics to be covered in the rest of the webinar series include antimicrobial stewardship, polypharmacy, new legislation and obligations for providers regarding restrictive practices with a focus on chemical restraint, quality improvement initiatives that pharmacists can participate in, how pharmacists can support providers to ensure medications are managed appropriately, and the National Aged Care Mandatory Quality Indicator Program.

These webinars are open to pharmacists and anyone working in the aged care sector. Keep an eye out on our Facebook, LinkedIn and Twitter channels for details about each of the planned webinars as their scheduled date approaches, including how to register your attendance.

Free course about providing culturally responsive care to older people

The Migrant and Refugee Health Partnership has developed the free online course ‘Culturally responsive practice with older people in health and aged care’.

This course is designed to complement the skills and capabilities of clinicians and health practitioners working in aged care and health care settings with the knowledge to provide culturally responsive care to older people from migrant and refugee backgrounds.

This course was developed in partnership with the Monash Centre for Health Research and Implementation, and is also supported by the Australian Government.

This free 5-6 hour course is suitable for all clinicians and health practitioners, and it attracts Continuing Professional Development hours with several peak bodies.

For more information and to enrol, go to myauslearning.org.au/aged-care