Response 414604172

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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
Home Modification Australia

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

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(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
Ticked 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
Ticked NSW
Ticked VIC
Ticked QLD
Ticked WA
Ticked SA
Ticked TAS
Ticked ACT
Ticked 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
Ticked Regional
Ticked 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
Text box for suggestions about improving consumer outcomes
Home modifications are one-off, very specialised, technical and sometimes expensive interventions upon the home environment, which are effected to achieve an outcome of safety and functional independence for the eligible individual. The standards are designed for services which are more directly engaged with individuals with a range of actions and supports effected upon the person, and often assume an ongoing relationship. It is important over time to build up the awareness of people about the need to make their homes safer and more functional so they can age in place, and when this occurs it may be possible to increase their knowledge about the technical aspects of home modifications so they can understand and make decisions about their options. Currently there is little awareness amongst consumers, and this leads me to respond that the process issues covered by the standards are not as relevant, yet, to consumers for home modifications as they are for, say, domestic and personal care services.

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
With regard to the statements for consumers and organisations, this is a good way to succinctly express expectations, although for many support options, including the delivery of home modifications, the outcome is important but the involvement of the consumer within the process is arguably more important when it comes to measuring and delivering quality. Likewise, the reference in all standards to needs, goals and preferences are relevant to home modifications, but an additional dimension which is critical to quality is the concept of “co-design”. These two observations perhaps point to a deficit within the standards to actually identify and measure quality within home modifications, which is not unexpected as it is an intervention which is targeted upon the home environment, rather than focusing on ongoing care and support for people living within. Home Modifications Australia (MOD.A) is developing its own Quality Standard to address particular quality factors relevant to home modifications, which it is intended will be compatible with the approach taken in the current draft of the Aged Care Standards. Clarification is sought about one aspect of the definition of “workforce”, namely the inclusion of tradespeople “who perform work other than under the control of the organization” not being considered as part of the workforce. Within some models of operation of home modifications contracted tradespeople are a critical component of the design and build, and it is important for those regularly contracted to do the work to be properly accredited and compliant with the requirement of certain aspects of these and other standards. The MOD.A Quality Standard will endeavour to draw the relevant boundaries for the various tradespeople in terms of their requirement to comply with aged care, disability and other standards.

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
MOD.A does not have a problem with the fact that the proposed Standards are at a level of generality which does not really allow for accurate measurement of a range of diverse services, on the proviso that the new framework will accommodate industry-specific quality standards which are verifiable and can be used to demonstrate compliance with broader standards such as Aged Care and Disability Services. This is addressed later in the survey, but MOD.A's support for the new framework is contingent upon the allowance of it,and other industry components which contribute to multiple sectors including the aged care sector to develop its own quality framework which accurately identifies the areas of quality that matter. In brief for home modifications this includes the delivery of well designed and built home modifications without delay and at reasonable cost, as well as meeting all of the other consumer-focused and organisational requirements which are specified generally in the aged care standards. The approach MOD.A proposes is compatible with existing Disability Service quality regimes, and so we would expect that aged care standards would be amenable to this approach as well.

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
Specifically for home modifications they can never capture the detail of the process, the importance of collaboration which lies at the centre of quality for home modifications, This is what the MOD.A Quality Standard aims to achieve, and a set of aged care standards which providers need to comply with, but can demonstrate that compliance through a more thorough and relevant quality system is what MOD.A is seeking as the result of this process of reform.

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
MOD.A believes that the expression of the Standards is clear, and user-friendly, but we have specific comments to make about the wording, which are provided in the sections below.

15. Are any draft standards or requirements NOT relevant to the following services? If so, please provide details below.

Text box reason why stanard is not relevant
MOD.A is supportive of the application of only five of the eight standards to all services which seek to operate with government funding, with some reservation about the wording and focus of some which are not strictly relevant in their current form to quality in home modifications. Particular issues will be articulated in the following sections, looking at each of the five “common” standards. The three specialist standards (3,4 and 5) are not relevant to home modifications and will not be addressed.

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
The strengths-based and empowerment model, emphasised within the concepts of dignity and respect, is not as relevant to the way in which home modifications are applied as it is, say, to the ongoing provision of assistive support, such as personal and domestic care. It will be important to identify where existing strengths can be exercised, which is mainly in the decision-making processes, but cannot be extended to active engagement within the building processes. Generally the expression of dignity and respect fits well within the outcomes that home modifications are designed to achieve. MOD.A is concerned, however, that these outcomes can only be guaranteed if not only the service provider delivers a quality product, but the funding and administrative settings of the home-based aged care system are such that consumers have access to what they need to the extent they require it and can afford to pay. The acknowledgement of diversity in identity and culture is important for home modifications providers when assisting a consumer to determine the changes to be made to the home, to assist them to be as functionally independent as possible, but also to feel a sense of pride and ownership of their home environment. The psychological wellbeing of a person is arguably as important as their physical wellbeing, and home modifications providers need to be able to offer a range of options to enable this. Again, programme and funding limitations have in the past dictated a basic model approach to the delivery of home modifications, and if the standards are to measure to a greater extent consumer input and to hold services accountable for this, government programmes must acknowledge and adequately resource the desirable outcomes for the home environment. The provision of home maintenance can be a more regular engagement with clients, so ongoing relations should meet the required standards. In terms of choice, however, programme and funding limitations appear to be the main barrier to enabling flexibility of choice for consumers, e.g. services prioritising consumer requests based on availability of remaining grant funding, and delivering maintenance services which are prescribed in the CHSP Guidelines, whereas consumers have been told through MAC they are able to get an alternative service such as hedge trimming or dog shampooing. The standards appear to anticipate a time when consumer will have more choice than is currently the case and, more importantly, providers are funded and encouraged to go outside of the current programme guidelines to deliver according to consumer choice. Unless this occurs services will be unfairly and negatively assessed with regard to consumer choice. Finally, with regard to the opportunity to take risks, whilst this is an important and worthy principle for ongoing service delivery (as it speaks to empowerment), it is not suitable for home modifications, both in terms of the engagement of the consumer with the work, and in terms of decisions taken to utilise programme funds for purposes other than those which they are intended. This is an emerging issue within the NDIS, where design specifications, and agreed costs attached to these, can be expended on building to alternative designs. Arguably choice in design in the home environment is fundamental to empowerment for the individual, but it is possible to strictly implement the funded works and allow for variation of that work at the cost wholly to the consumer.

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 main issue with this standard for home modification providers is the nation of “ongoing”, when the intervention is, by its nature, one-off. The requirements appear to necessitate systems and processes which attest to the ongoing planning and review of broad goals for an individual over time. For ongoing maintenance services this may be appropriate but for one-off home modifications and maintenance services it is less so. There are discreet processes within the delivery of a home modification, which can and will be quality checked through the MOD.A Quality Standard, and if it is possible to apply this to Draft Standard 2, this would work. The important principle of partnering with the consumer will be an important marker of quality for home modifications going forward, and the involvement of the consumer in the assessment process is also relevant, but specifically in relation the specialist assessments which identify the needs of the individual within the home and address these in line with the consumer’s personal goals and wishes. In order for the standard to be more applicable to home modification providers MOD.A recommends the wording of the consumer outcome statement be changed to: I am a partner in the assessment and planning of my care and/or services.

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
This standard is not relevant, and it is vital that home modifications services are not measured against this.

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
This standard is not relevant, and it is vital that home modifications services are not measured against this.

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
This standard is not relevant, and it is vital that home modifications services are not measured against this.

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 needs to be some requirement for services to guide consumers toward existing complaint resolution frameworks which may exist outside of the aged care system. Home modifications can involve significant building work, which is covered by codes and regulations administered by state government departments, such as Fair Trading NSW and the Queensland Building and Construction Commission. Consumer protections vary from state to state, and it is arguable that they suffice to provide vulnerable older people with adequate safeguarding, but services should still be required to provide consumers with as much information as possible about how disputes may be pursued through these mechanisms. MOD.A has communicated with the Aged Care Complaints Commission about the cross-jurisdictional nature of some home modifications complaints, and it should be possible for most complaints to be coordinated through the Commission. And there needs to be greater understanding by the Commonwealth Department of Health about the requirements for funded and approved service providers to procure and deliver home modifications (requiring a building contract) according to the building regulations set out in each state and territory.

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
This standard has some overlaps with the proposed MOD.A Quality Standard, and the nature and interrelationship of the workforce will be a significant focus of our own work on quality. The expression “people who are knowledgeable and considerate” will not adequately cover the strict licensing and other requirements of builders, tradespeople and occupational therapists who work in this specialised area. The general requirements to nurture and build a workforce, and to require particular attributes and attitudes is not contested here, but additional requirements of the industry will not be adequately captured within the standard as it is currently expressed. MOD.A does not have a difficulty with this, but it will be critical to understand how services are to be assessed for quality and by whom, as it is our preference to have auditors who have the capability to critically appraise the systems applied in home modifications, and the outcomes achieved objectively and from the subjective view of the consumer.

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
Overall the standard provides no problems for providers of home modifications, except the requirement to partner with consumers in the “planning, delivery and evaluation of care and services”. There is a dearth of information available currently to consumers of home modifications to assist them to make informed choices and decisions about their own supports, and a correspondingly small pool of “expert” consumers nationally who could provide the sort of technical input to the governance oversight of services which are focused exclusively upon home modifications. MOD.A is certainly not opposed to the principle behind this requirement, and welcomes the challenge to identify the best way to infuse home modifications service governance with consumer input. It is likely, however, that the source of this expertise will have to be found amongst consumer groups which might not be traditionally called upon to sit in governance roles within organisations, to avoid tokenism.

Other Comments

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

Text box - any other comments or suggestions
As has been articulated already, MOD.A is broadly supportive of the new Framework and believes the expression of the standards, and the fact that not all are relevant across the board, is a very positive step forward. It is crucial, however, that they are able to accommodate real quality frameworks such as that proposed by MOD.A for its industry, to enable genuine continuous improvement processes to embed themselves in the new home-based aged care sector, and for MOD.A's member services to use this as the primary mechanism to demonstrate their compliance with the Aged Care Quality Standards and any other quality standards relevant to other funding programmes.