Response 411699494

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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
North and West Metropolitan Region Palliative Care Consortium (Melbourne, Victoria)

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

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
Ticked People who are veterans of the Australian Defence Force or an allied defence force including the spouse, widow or widower of a veteran
Ticked People who are homeless, or at risk of becoming homeless
Ticked People who are care leavers (which includes Forgotten Australians, Former Child Migrants and Stolen Generations)
Ticked Parents separated from their children by forced adoption or removal
Ticked 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
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
Ticked Yes, mostly
Yes, sometimes
No
Don't know

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

Please select one item
Yes, always
Yes, mostly
Yes, sometimes
Ticked No
Don't know
Suggestions - are organisational statements and requirements achievable
It will be difficult for Approved Providers to meet the needs of all residents with current number and skill mix employed within the sector. Our frail aged residents often have complex and competing needs as well as fluctuating cognitive abilities so the organisation statements may be goals that should be achieved but there needs to be recognition that this may not always be possible, despite the best efforts of staff.

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
Having a "tick box" approach to demonstrate that residents or their representatives have been given options/ choices does not demonstrate that the parties have been offered appropriate information and support to make those decisions. For example.. I may have a tick box Advance Care Plan that is offered to all residents and their representatives on admission. These may be completed with limited support from the aged care facility or with little knowledge of what is being completed. During a process of accreditation, I may be able to demonstrate that all residents either have a completed form or have been offered one, but this is not an indication of the quality of discussions that have been held around this topic or the impact this has on the residents care or outcome. Every time a specific item/ issue is listed, there may be a tendency to "create" a new tick box form to comply. I think it is critical to recommend the use of validated assessment tools, programs and tools from a reputable source (such as Advance Care Planning documents, end of life care pathways, pain/ symptom assessment tools). Using the term best evidence does not convey the need to use tools/ programs that are robust and validated tools. Many of the current computer based documentation systems do NOT have validated assessment tools. Therefore the evidence and assessments used are frequently irrelevant or focussed on providing evidence for ACFI documentation and not informing care 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
No mention to the needs of residents with a diagnosis of dementia. No mention of behaviour management. Greater that 50% of the residents have a dementia diagnosis, surely dementia care is an area that warrants some attention. When addressing risk within the aged care facility, surely some of it will come from the behaviours of individuals with altered cognitive processes. Management of aggression, confusion, agitation/ restlessness or other associated behaviours are time and resource intensive. These need to be alluded to in the standards to ensure Approved Providers continue to see the importance of the efforts of staff to maintain a safe and respectful environment for all staff and residents. There is a mention under Standard 3 regarding "unexpected change or deterioration". Diseases such as dementia and the general frailty of our aged often leads to a slow decline where deterioration occurs over time. Deterioration with these conditions is expected to be slow. Are these episodes not considered worthy of management as well? By focussing on the sudden or unexpected decline of residents, we are looking at being reactive in these situations, whereas monitoring and responding to all deterioration (both expected and unexpected) should result in earlier identification of deterioration, assessment and management of all current and potential issues resulting in improved quality of life and resident outcomes. In other words, this part reads like you are focussing on the urgent and not the important, as all deterioration should be considered. Reacting to sudden or unexpected deterioration may be relevant to the acute sector BUT aged care where the residents are with the facility for an extended period of time, SHOULD be reinforcing the predictable and progressive nature of the diseases prevalent in the aged population. Surely the implementation of a palliative approach where deterioration is identified and managed is more appropriate.....

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

Please select one item
Yes, always
Yes, mostly
Yes, sometimes
Ticked No
Don't know
Text box for suggestions about how wording and intent could be improved
Too closely aligned with the National Standards.. The aged care sector is different. It is funded less, staffed less and has people who are expecting to decline and then die. We cant reverse ageing, dementia or end stage organ failure BUT we need to manage it effectively and with the utmost respect to the resident and their representatives.

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
It may be beneficial to mention the consumer or their representative a little more. It would also be beneficial to ensure that the "Specified Care and Services" is referred to to ensure all residents or their representatives are aware of the minimum services/ equipment that are to be provided (preferably before contracts are signed).

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 assessment needs to be conducted by an appropriately qualified and skilled person using validated assessment tools. Advance care planning needs to be offered by a skilled practitioner using recognised tools/ programs..

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
The ongoing and slow nature of deterioration associated with the aged population is not recognised. A focus on sudden or unexpected deterioration demonstrates no understanding of slow deterioration of this population. ALL deterioration should be acted on and the appropriate assessments and planning occur in order to identify and pre-empt future care needs. Care should be about anticipating and preparing for the inevitable decline experienced by our frail elders, not about waiting for a crisis or "unexpected" deterioration. In light that many residential aged care facilities do not provide handover time for personal care workers, communication of the elders specific care requirements needs to be conducted in a manner that ensures all care is identified and offered as planned. By identifying the "risk" behaviours (falls, choking, medication, delirium, pain management, pressure injuries, malnutrition and dehydration), there is the potential that these will be focussed on rather than looking at all potential risks which may be relevant to individuals. Also by identifying these risks, there is potential for some unnecessary and expensive referrals to allied health and other professionals, without there being evidence as to the efficacy of this practice. There is no mention of dementia care or behaviour management. In light of this facilities may be tempted to focus only on behaviour as it relates to a funding system and not look at the needs of the individual or other residents. The importance of case conferencing or discussing care needs with residents or their representatives is not clearly iterated in this 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
Residential facilities need to have resources available for residents and their representatives to use that enable continued relationships. these may include but are not limited to - private dining room - family room - quiet/ meeting room - an area for family/ friends to stay in comfort when attending to an unwell/ deteriorating resident Rooms need to be fit for purpose. Large enough to accommodate equipment. Private enough to facilitate the comfort and dignity of the dying (including accommodating family/ friends). Modern aged care facilities often are decorated in a way to attract the attention of the children of their potential clients. Facilities are often not clearly signposted or designed for people with cognitive decline in mind. 160 beige rooms all look the same to a frail elder with dementia. Facilities should be designed and decorated in a manner that assists elders to locate their home.

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
There must be demonstrated evidence that recommendations made by consumers are acted on and implemented where appropriate.

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
Once again, the generic statements with regard to "sufficient workforce to deliver and manage safe quality care and services", will allow facilities to have loose interpretations of what sufficient actually means. As there are no mandatory minimum staffing levels, this standard needs to be bolder to ensure the auditing authority has some clarity around what is sufficient..

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
The role of clinical governance is imperative in providing good quality care to residents. The voice of the clinical leaders in residential aged care needs to be encouraged so that it is not overrun by the non clinical managers.

Other Comments

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

Text box - any other comments or suggestions
My concern is that we are encouraging approved providers to be reactive to the clinical care needs of their residents. The focus of a care not cure principle (in other words a palliative approach) would be more appropriate so that the slow and gradual decline of our frail alders can be identified, managed and prepared for. We will no doubt see a large number of elders being referred to dieticians, speech pathologists and physiotherapists creating a big industry for them but there are times when simple approaches such as - having food available for residents outside of the normal meal times - extra hands to help with the nutritional requirements of our frail elders - favoured foods on offer and at times an acceptance that the decline may be due to the fact that the resident is dying, albeit slower than people die in hospital..