Response 157071724

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Introduction

2. Are you answering on behalf of an organisation? If so, please provide your organisation's name.

Please select one item
Ticked Yes
No
Organisation
The Multicultural Network

3. Do you give consent for your submission to be published in whole or in part?

Please select one item
(Required)
Ticked Yes
No

More detail about you

4. What role best describes you? Please select all that apply.

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
Ticked Other - please specify below
Text box to add other roles
Sector Support Development Officer

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.

Please select all that apply
Ticked People from Aboriginal and/or Torres Strait Islander communities
Ticked People from culturally and linguistically diverse (CALD) backgrounds
People who live in rural or remote areas
Ticked 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.

6. Where do you live, or, where does your organisation operate? Please select all that apply.

Please select all that apply
Ticked NSW
VIC
QLD
WA
SA
TAS
ACT
NT

7. What is your location, or, the location where your organisation operates. Please select all that apply.

Please select all that apply
Ticked Metropolitan
Regional
Rural/Remote

General questions about the draft standards

10. Do the consumer outcomes in the draft standards reflect the matters that are most important to consumers?

Please select one item
Yes, always
Yes, mostly
Yes, sometimes
Ticked No
Don't know
Text box for suggestions about improving consumer outcomes
The new quality standards that will apply to all aged care organisations need further scrutiny given the profound impact they will have on what will be assessed and what quality framework option should be adopted. In relation to residential care the new 8 standards represent a significant reduction of clinical standards. This is a dangerous step backwards that will most likely placing at risk health and quality of life outcomes for older people in residential care. For older people in community care the proposed standards are weak and do not provide a robust base for quality review and monitoring of aged care services. We are dealing here with very vulnerable people and the standards' emphasis on consumers' exercising choice and accessing services that are "right' for them puts the onus on consumers' capacity to make informed choices rather than on the responsibility of services to deliver quality programs that ensure people can remain at home and maintain their quality of life. The likelihood result of the proposed standards is that organisations will be exonerated from any responsibility for poor consumer outcomes. Critical outcomes in personal and clinical care should not be left to the consumer to articulate but there should be clear and evidence based indicators of optimal care. Currently the proposed standards state the organisational outcomes of clinical and personal care as: "Personal care and clinical care services are delivered in accordance with the consumer’s needs and preferences to optimise health and wellbeing and to maximise the consumer’s function". An organisation that fails to meet this vague standard can cite consumers' poor choices as the reason for this outcome, when the actual issue is the consumer's limited capacity to assess and identify their own needs. It is recommended that the Department of Health considers revising the proposed standards under the light of issues raised , and the nature of the services being delivered and most importantly, the vulnerability of the service users. In hospital care we don't frame standards around patient's choice and preferences and although we could certainly benefit from listening to patients and having a more person centred care approach to allied and primary health, the standards need to be robust and focused on clear and measurable indicators of high quality clinical and personal care.

11. Are the organisation statements and requirements in the draft standards achievable for providers?

Please select one item
Yes, always
Ticked Yes, mostly
Yes, sometimes
No
Don't know

12. Are the draft standards measurable?

Please select one item
Yes, always
Yes, mostly
Yes, sometimes
Ticked No
Don't know
Text box - suggestions are draft standards measurable
please refer to answers below

13. Are there any gaps in the draft standards? If so, what are they?

Please select one item
Ticked Yes
No
Text Box for gaps in draft standards
As pointed above.

14. Is the wording and the intent of the draft standards clear?

Please select one item
Ticked Yes, always
Yes, mostly
Yes, sometimes
No
Don't know
Text box for suggestions about how wording and intent could be improved
yes. the wording is unambiguous but the intent might not be clear, as the potential result of the proposed standards include decreasing consumer protection and limiting responsibilities of service providers to deliver high quality care that meet robust and evidenced based standards of clinical and personal care.

Specific suggestions about each draft standard

16. Do you have any specific suggestions in relation to draft Standard 1: Consumer dignity, autonomy and choice? If so, what are they?

Text box Standard 1 Consumer dignity, autonomy and choice
Standard 1 is a process outcome - how services are delivered. It is important to have process outcomes but it should be under the umbrella of quality of life outcomes which encompasses process as well. Outcome 1 should read: I am treated with dignity and respect, and the services I receive help me maintain my health, wellbeing and quality of life . I'm entitled to being supported to understand and make informed choices about my care and services and how they support me to ensure I can live a meaningful life. Organisation statement should read: The organisation: • has systems in place to identify, address and evaluate interventions that meet the health and needs of consumers . These services and interventions are delivered within a culture of inclusion, acceptance and respect for consumers • supports consumers to exercise choice and independence.

17. Do you have any specific suggestions in relation to draft Standard 2: Ongoing assessment and planning with consumers? If so, what are they?

Text box suggestions in relation to draft Standard 2: Ongoing assessment and planning with consumers
The Organisational statement is limiting quality of programs or services delivered as relies on consumer's understanding rather than enhancing assessment, planning and care with input from robust clinical and wellbeing indicators. The Organisational statement should read: The organisation undertakes initial and ongoing assessment and planning for care and services in partnership with the consumer. Assessment and planning has a focus on optimising health and wellbeing in accordance with consumers' needs and preferences and robust clinical and quality of life indicators.

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?

Text box suggestions in relation to draft Standard 3: Delivering personal care and/or clinical care
Standard 3 is concerning due to the reduction of specific clinical indicators contained in the current 44 standards for residential care. Specific requirements around dental care, continence management and palliative care and specialised nursing care have been stripped from the proposed standards. These specific clinical standards protect consumers and place consumer at risk of premature impairment and deterioration of health that can be delayed or prevented with appropriate clinical care. The proposed standards state in point 3.7: Identification and management of high-impact or high-prevalence risks associated with the care of each consumer, including but not limited to falls, pressure injuries, medication misadventure, choking, malnutrition, dehydration, pain and delirium. The concepts of "identification and management" are vague and do not provide clear direction to service providers to deliver effective treatment or intervention to address issues. It merely addresses the need to act or manage a situation but does not ensure compliance with quality care that can prevent or clinically manage a deteriorating condition. We support retaining the current 44 standards state the following in relation to clinical standards: 2.10 Nutrition and hydration: Care recipients receive adequate nourishment and hydration. 2.12 Continence management: Care recipients’ continence is managed effectively 2.13 Behavioural management: The needs of care recipients with challenging behaviours are managed effectively. 2.14 Mobility, dexterity and rehabilitation: Optimum levels of mobility and dexterity are achieved for all care recipients. 2.15 Oral and dental care: Care recipients’ oral and dental health is maintained. 2.16 Sensory loss: Care recipients’ sensory losses are identified and managed effectively. 2.17 Sleep: Care recipients are able to achieve natural sleep patterns. We endorse the use of clear directions and standards of treatment such as the ones contained in the current standards that prescribe "optimum and effective" in the delivery of care.

19. Do you have any specific suggestions in relation to draft Standard 4: Delivering lifestyle services and supports? If so, what are they?

Text box suggestions in relation to draft Standard 4: Delivering lifestyle services and supports
Standard 4 states the following outcomes: Consumer outcome I get the services and supports I need to help me do the things I want to do. Organisation statement The organisation facilitates the consumer’s access to services and supports that enhance wellbeing and quality of life. This outcome might be too general and potentially reduce consumer protection. "The things I want to do" for many older people in the community means being able to remain at home for as long as possible and live a meaningful live. However most older people do not articulate their wants using this capabilities' approach. Instead they tend to focus on outputs or services like meals on wheels or home care. Getting consumers to focus on outcomes or quality of life requires specific initiatives and leadership from case managers and care providers. This is not stated in the Organisational statement and again service providers can excuse themselves from any responsibility for poor outcomes by citing "consumers' choice".

22. Do you have any specific suggestions in relation to draft Standard 7: Human resources? If so, what are they?

Text box suggestions in relation to draft Standard 7: Human resources
Standard 7 does not provide enough protection for consumers from unqualified staff, particularly for the delivery of specialised and clinical care. The consumer outcome as stated in the draft standard 7 is: "I get quality care and services when I need them from people who are knowledgeable and considerate". Consumers need staff who are qualified as well as knowledgeable and considerate. Minimum qualification standards need to be specified. The Organisation statement mentioned a qualified workforce but fails to specify what "sufficient" means. There is a need to specify the ratio of staff-residents for consumers in residential care and consider in this ratio the inclusion of high and low care needs as they would also be determinants of staff numbers and availability. It is highly documented that there is evidence of limited availability of staff in relation to residents in many nursing homes.

23. Do you have any specific suggestions in relation to draft Standard 8: Organisational governance? If so, what are they?

Text box - suggestions in relation to draft Standard 8: Organisational governance
Proposed standard for consumer outcome states: I am confident the organisation is well run and that the consumer voice and experience is sought and heard. We proposed to add that the consumer voice and experience and that of their families' or advocates' is sought and heard. The rational behind this proposal is that many older and fragile residents are unable to articulate their concerns or advocate for themselves

Other Comments

24. Do you have any other comments or suggestions about the draft standards?

Text box - any other comments or suggestions
We are concerned that the draft standards could potentially reduce consumer's rights to quality care, increase risk and deterioration of health and wellbeing. The drastic reduction in the number of critical clinical standards such as palliative care, dental care and continence management will leave consumers at greater risk of neglect and potentially leading to detrimental health outcomes or rapid decline of health. Important interventions such as medication management, skin care, pain management, nutrition and dehydration can be delivered by non clinically qualified staff under the proposed standards, creating a higher risk to residents. Dementia specific care is also absent from the standards despite the overwhelming evidence pointing to the specific and specialised needs of increasing number of aged care recipients with dementia. This again places consumers at risk of receiving care that does not address their clinical needs. The absence of requirements for specialised nurses is also alarming given their role in meeting clinical and health needs of consumers. The emphasis on "doing what the consumer wants" permeating all of the standards could potentially favour the principle of consumers' choice in detriment of safety and quality of care. It also limits service providers' responsibility to identify and pursue quality interventions that meet clinical, health and social care related quality of life outcomes.