Response 716665179

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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?

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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
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
Ticked 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
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
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
Metropolitan
Ticked Regional
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
Ticked Commonwealth Home Support Programme services
Transition care
National Aboriginal and Torres Strait Islander Program services
Ticked Multi-purpose services
Innovative care services
Short term restorative care services

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
See below

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

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Yes, always
Yes, mostly
Ticked Yes, sometimes
No
Don't know
Suggestions - are organisational statements and requirements achievable
Human and financial resourcing issues remain one of the biggest barriers as well as the capacity for clinical leaders to be given a legitimate voice to enable evidence based decision making in the sector. The strong reliance / acceptance of a GP model of care rather than an Nurse Practitioner partnership, whereby NP's are a legitimate health care partner with all providers, including GPs, remains a barrier. At this stage great emphasis remains on unit rather than episode costs in health and no more an issue is it than in the aged care sector.

12. Are the draft standards measurable?

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

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
I am an advanced practice nurse in a clinical consultancy role, covering a total of 29 CHSP and Public Residential Aged Care campuses in regional / rural Victoria. The program is funded by CHSP and the program aims are to improve skin integrity / wound healing outcomes in consumers of both CHSP and Public Residential Aged Care Services by increasing clinical capacity. Just as efforts are being made to consolidate the aged care standards into a single framework, that support a single aged care system, I urge the adoption of a single skin integrity framework into these standards to support a single skin safety model. Pressure Injury is just one skin integrity issue, among others including skin tears and Incontinence Associated Dermatitis (IAD) that have an associated high rate of morbidity and mortality. Please see that attached papers. The first discusses the skin safety model and the clinical and systemic imperatives. http://onlinelibrary.wiley.com/doi/10.1111/jnu.12176/pdf The next two links are dedicated to reducing the harm of skin tears as well as discussing the equivalent clinical import to pressure Injury http://search.informit.com.au/fullText;dn=273076010394786;res=IELHEA http://www.skintears.org/ The final link is a paper discussing the blurring of boundaries between IAD and Pressure Injury. http://www.woundsaustralia.com.au/journal/2403_05.pdf

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
See specific feedback below

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
pp 16 and 17 With respect to the use of the term “informed choice” can an operational definition be provided in the glossary as I believe there is a great deal of ambiguity in the statements including these words. There is comprehensive information on the WHY and HOW of "informed choice" in the document but I cannot see evidence of a working definition of WHAT is an “informed choice”. In my opinion, herein lies the inextricable link between 1) “dignity of risk”, 2) informed choice (however it is defined) and the 3) decision-making capacity at that particular time.

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
Pp 20 and 22 Can the reference to pressure injury be broadened to overall Skin Safety, see link provided above, as research is identifying that mortality and morbidity to other issues such as IAD and Skin tears are commensurate with PI. Additionally, the skin should be considered as one organ with multiple threats to morbidity and mortality when its integrity is breached, including life-threatening amputations and infections, especially in the older person. P 21 “Under clinical care is best practice” include an “Equipment and consumables category”: to ensure purchases and resourcing are evidence-based, and focused on episode cost, rather than unit cost. OR include this statement in pp 26 – 27 in “Service environment”. I witness millions of dollars of waste on an annual basis with the respect to the purchase of cheap dangerous equipment, rather than procurement, supported by evidence-based decision purchasing, in consultation with clinical leaders. Pp 21 replace the word “strong” as it appears the first time on this page with “comprehensive, best-practice”. In the second use of the word “strong” p 21 please be more specific or define the meaning of “strong” in this context. P 22 Can the skin safety model and ISTAP evidence provided be included in this paragraph under the heading Skin Safety, rather than simply pressure injuries? P 23. Under last dot point rather than “such as measures to reduce the risk of urinary tract infections or TREAT MINOR SKIN INFECTIONS” be replaced with (such as measures to reduce the risk of urinary tract infections and BEST PRACTICE SKIN HYGIENE) as the former is a downstream strategy rather than a preventative strategy. p22. As a former pain management consultant I am disappointed that pain is not profiled as a priority in terms of its positioning in the document or the words dedicated to it. Please contact the Australian Pain Society president particularly in relation to the latest evidence and pain in cognitive impairment. Pain and it's manifestations ( elderly may exhibit pain behaviours but not necessarily be able to articulate pain) are the most commonly presenting symptoms in an emergency department so why would it not be the most commonly discussed issue in this section of the framework? The words dedicated to "pain", as opposed to the other categories on this page, align to the level of care I witness in aged care. I suggest that "pain" is inserted as the highest priority because falls, skin tears, IAD are associated with mind altering, distressing, life-ending pain phenomena and people with cognitive impairment /delirium are the least likely to be able to communicate it. Furthermore one of the most common medication misadventures are related to analgesics. Even an overarching statement highlighting the pervasive clinical issues of pain may well be worthwhile. I hope this helps.

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
See response in Q18 as option presented for either Draft Standard 3 or 5

Other Comments

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

Text box - any other comments or suggestions
This is a very easy to read, relevant and progressive document that I could very readily incorporate into my role. My only other suggestion is that I see a great deal of burn out in the sector as clinicians try to do their best to support a consumer-focused framework. I appreciate statement 7.3 in the framework, "The workforce is supported, trained and equipped to deliver the outcomes required by these standards", however how is this "support" measurable and articulated to governance structures as a priority?