Response 369088036

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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
Yes
Ticked No

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
Ticked Aged care worker/professional
Aged care advocate
Peak body - consumer
Peak body - provider
Peak body - professional
Other - please specify below

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
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
Ticked Yes, sometimes
No
Don't know
Text box for suggestions about improving consumer outcomes
Refer to comments regarding standards 7 & 8

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

Please select one item
Yes, always
Yes, mostly
Ticked Yes, sometimes
No
Don't know
Suggestions - are organisational statements and requirements achievable
Refer to comments regarding standards 7 & 8

12. Are the draft standards measurable?

Please select one item
Yes, always
Yes, mostly
Yes, sometimes
No
Ticked Don't know
Text box - suggestions are draft standards measurable
I believe they are, however this will depend upon the tools which are developed for assessing and measuring how organisations will meet the standards

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
See comments re standard 7 & 8

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 of the intent is clear, however aged care services and particularly those who provide the face to face service, often, in my experience, have varying degrees of sophistication. Personally I find the standards too vague and was hoping for more certainty. This may come through in the tools which are developed.

Specific suggestions about each draft standard

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
The biggest failing in aged care, particularly residential, is the staff. Increasingly organisations are minimizing the employment of registered/enrolled nurses and making personal care attendants responsible for all aspects of resident care (ie undertake activities of daily living, medication administration, leisure and lifestyle activities and meal service - often without appropriate training in all of these aspects). This is done in the guise of maintaining continuity of care, particularly residents with dementia. However in reality, it's to save the organisation money. The result is overworked personal care attendants, with varying degrees of expertise and commitment to consumers, which results in attrition and increased taking of unplanned leave (often not replaced), which ultimately leads to lack of continuity of care.

The only way to address this is for the government to finally implement ratios. As the mass media is increasingly reporting failings in aged care, this matter will continue to be raised until it is addressed.

In my view, however, ratios should be included in legislation, rather than standards, which do not have the force of law.

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
I have consulted and assessed against many standards over the years, including the aged care accreditation standards, NSDS, Home Care Standards, and Victorian and Queensland human service standards. Without doubt, the best standards are the home care standards, which include robust governance requirements.

I am dismayed, however, to see how watered down the standards are with regards to governance. Consumers or the representatives don't know if an organisation is well run! They know if they don't like the food, or the care attendant doesn't show up to their house, but they have little to no knowledge regarding the corporate operations of an organisation. Where is the finance element?

There is an adage that "the fish rots from the head down". It is crucial, in any compliance based system, that the very top management is responsible and included in the standards. I would expect the see the credentialing of the CEO and senior managers are appropriate to manage the tax payer's money and residents/representatives payments. Board reports should be in scope for assessments, as they currently are under the Home Care Standards. Over the years I have come across instances of bankrupts who have been "silent" partners within the corporate operations of organisations, who are not picked up during the AP probity checks, as there are no "associated persons" test under the legislation.

Other Comments

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

Text box - any other comments or suggestions
I don't see why the Home Care Standards were not the basis for these draft standards. I suppose a few people in Canberra had to justify their position, so a project was launched to come up with a new a whole new set of standards.

There is no doubt that the residential standards are appalling and required redrafting, but there are gaps around standard 7 & 8, which really are the crucial ones, because if you don't get these right, standards 1-6 won't work properly.

I've been in the industry long enough to know that the government is getting, through directions to the accreditation agency, the results it wants regarding the state of aged care in Australia, rather than the reality. I sincerely hope that the government doesn't cave in to the threats of the strong AP lobby. They won't close down, they are still making bucket loads of money from tax payers and residents/representatives, so stand strong and let the market sort out the ones who won't measure up.