Response 202535672

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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
Sunnyside Lutheran Retirement Village

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
Ticked Aged care consumer, including family and/or carer
Ticked Aged care service provider
Ticked Aged care worker/professional
Aged care advocate
Peak body - consumer
Peak body - provider
Peak body - professional
Other - please specify below

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
People from Aboriginal and/or Torres Strait Islander communities
People from culturally and linguistically diverse (CALD) backgrounds
Ticked 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.

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

Please select all that apply
NSW
Ticked 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
Metropolitan
Regional
Ticked Rural/Remote

8. If you are an aged care service provider, please select all the types of care your service delivers.

Please select all that apply
Ticked 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

9. If you are an aged care service provider, which option below best describes the size of your organisation?

Please select one item
Small
Ticked Medium
Large
Very large

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
Ticked Yes, mostly
Yes, sometimes
No
Don't know
Text box for suggestions about improving consumer outcomes
Most of the outcomes are the most important to consumers. I think there just may be an over emphasis on consumer choice, as many particularly in residential aged care are either not able to make effective choices, or do not wish to.

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
Suggestions - are organisational statements and requirements achievable
The organisation statements would be currently being achieved in most services as they are reflected in the current outcomes. The wording may have changed lightly, but the intent of the current standards has not been changed greatly in my opinion.

12. Are the draft standards measurable?

Please select one item
Yes, always
Ticked Yes, mostly
Yes, sometimes
No
Don't know
Text box - suggestions are draft standards measurable
Some of the draft standards will be somewhat difficult to measure, particularly those around resident choice. For example under draft standard 1.3: "Consumers are able to (or, when needed, supported to): (a) exercise autonomy, (b) Exercise choice and make decisions about their own care and the way that care and services are delivered, (c) make connections with others and maintain relationships of choice. However this may conflict with the requirements of standard 2 and 3, particularly the consumer outcome in standard 3 "I get personal care and/or clinical care that is safe and right for me." There will need to be an adjudication over what constitutes a reasonable choice for the consumer, and care that is appropriate to their needs.

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 above, the gaps are the grey areas between choice and appropriate care.

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

Please select one item
Yes, always
Ticked Yes, mostly
Yes, sometimes
No
Don't know
Text box for suggestions about how wording and intent could be improved
The wording and intent is fairly clear, but the concern is still around the consumers choice. This is a big concern, and while I am certainly not advocating that there should not be choice, I think that the standards need to make it perfectly clear as to where the ability to chose is over-ridden by the requirement to provide appropriate, safe, and legally compliant 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
As previous - there do need to be some boundaries around choice. I think that this standard has lots of grey areas and definitely needs to be very specific about what the repercussions to the service may be if some of the choices that may be made by a consumer turn out to be detrimental to their wellbeing. There is not time to have an inquiry into every decision, and involve a third party. There needs to be some clarity in this standard and I don't think it is quite there yet. Consumers choices still need to allow staff to remain compliant with their roles and obligations particularly under their regulatory licencing.

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
No. I believe this is in line with the current standards.

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
No

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
Most of this is currently done. There are however some financial constraints that have to be taken into account, particularly with providing opportunities to participate in activities outside of the service. Many of our residents do this already, and are supported with assistance to arrange transport, and often with volunteer assistants going with them. In some cases though, where the level of care required by a resident dictates that care staff would need to be present, there may well need to be a contribution from the consumer. This needs to be spelled out as part of the standard.

20. Do you have any specific suggestions in relation to draft Standard 5: Service environment? If so, what are they?

Text box - specific suggestions in relation to draft Standard 5: Service environment
No

21. Do you have any specific suggestions in relation to draft Standard 6: Feedback and complaints? If so, what are they?

Text box suggestions in relation to draft Standard 6: Feedback and complaints
No

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
No

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
No

Other Comments

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

Text box - any other comments or suggestions
I think that the rationale behind this proposed change is good. I don't think it will provide any reduction in compliance requirements, apart from the services that operate across different care types, who will now only have one set of standards to work with. From a Residential Aged Care perspective, I don't think it is realistically going to change anything. Most of the new standards are basically covered by the existing standards, and there are no radical changes to the services that are currently delivered. There is a heightened emphasis on the choice of the consumer, and I think there needs to be significantly more work done on that area, which could develop into a minefield where choice could over-ride safe clinical care for example. This change also comes at a time when ACFI income has been frozen for the forthcoming financial year, and I am not sure that there is any recognition of the enormous amount of work that will be required to put the new standards into place in every service across the country. Every single policy and procedure will need to be at least, reindexed, at worst re-written to reflect the new standards. This is going to be a massive undertaking in every service, and will require significant resources directed to it. There should be a monetary contribution to this work, particularly coming at a time when many (particularly rural and remote, not for profit) services are struggling already from a financial perspective, and this will be an additional burden on already stretched resources. It is a bit like a pyramid selling triangle - the work multiplies the further down the pyramid you go. The effect of a 36 page booklet of new standards will require thousands of paged in each of thousands of services to put in place. Finally, there is a lot of reference to consulting with consumers on the new standards. I have not seen this consultation advertised to consumers, and I don't believe many would be able to comprehend the discussion paper document - I am not sure that I am able to!! Most of the consumers in the service I represent, would not be able to, and would also not have the facility to respond. The survey is not suitable for the average consumer in residential aged care. To really take in the thoughts of the consumer, as opposed to carers and advocates, it needs to be in a form that they will understand, and be able to respond to. For example, a short, multiple choice survey, possible doing one or two standards at a time over a number of weeks. I would be very interested to see how many actual consumers respond to this consultation.