Response 749226533

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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
HammondCare

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
Ticked Aged care service provider
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
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
Ticked NSW
Ticked VIC
Ticked QLD
Ticked WA
Ticked SA
Ticked TAS
Ticked 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
Ticked 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
Ticked Home care
Ticked Commonwealth Home Support Programme services
Transition care
National Aboriginal and Torres Strait Islander Program services
Multi-purpose services
Innovative care services
Ticked 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
Medium
Ticked 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
The adoption of ‘consumer’ outcomes in the draft standards is a positive development. The consumer outcomes that are included in the consultation paper generally represent the issues that are most important to consumers. One area not addressed in any of the consumer outcomes is mental health and emotional wellbeing, both of which are significant to clients, carers, their families and carers. Another important issue for service users and their families that is not addressed in the consumer outcomes is effective communication. The Australian Aged Care Quality Agency’s ‘Let’s Talk About Quality’ report finalised in December 2015 noted that aged care residents, clients and their families “overwhelmingly agreed that trusting connected relationships, effective communication and an ongoing dialogue is at the heart of quality care” (page 17). There is an opportunity to include these principles more in the consumer outcomes for Draft Standard 2: Ongoing assessment and planning with consumers and Draft Standard 6: Feedback and complaints. The consumer outcome for Draft Standard 8 focuses on the governance of the organisation, when, in HammondCare’s experience, most ‘consumers’ are more concerned with how the service they use is run. However, we realise that a strong quality framework is underpinned by strong organisational governance.

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
HammondCare’s suggestions on how the organisation statements and requirements could be improved are addressed in the questions relating to specific draft 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
Most of the draft standards are drafted in a way that will make them easily measurable for providers. But there are some requirements that will be particularly difficult to measure and to demonstrate. These include the following provider requirements: - 2.3 – which talks about the need for care and services to be “continuously monitored”. This term is ambiguous and could be made clearer. - 6.4 – which talks about responding “appropriately” to complaints. The Complaints Commissioner has some perspective on how providers could demonstrate this. - 7.2 – which talks about the way that “each member of the workforce” interacts with residents, clients and family members. Further thought must be given to how this can be demonstrated.

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
The draft standards have a disproportionate focus on clinical and physical care and do not adequately address the mental health or emotional wellbeing of clients and residents. The current Accreditation Standards refer to ‘Emotional support’ (Expected outcome 3.4), which clearly recognises that holistic support is about more than simply providing good clinical care. The way in which an aged care service provides emotional support to service users should be incorporated into the standards, possibly in Standard 4.

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

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
The service types listed above are above are not always useful for determining which standards will apply in relation to different services. For example, Standard 5 should apply to some Commonwealth Home Support Program (CHSP) activities, and flexible care programs in some settings, but not others. As the consultation paper notes, Standard 5 should only apply where the organisation is delivering care in its own dedicated physical environment, such as in an aged care home or a day therapy service, and not in a client’s own home. This makes sense and it means that Standard 5 will be relevant for some CHSP activities (such as a day therapy service) – but not others (flexible respite delivered in the client’s own home or meal services). The same applies to Transition Care and Short-Term Restorative Care (STRC) services which may be delivered in a residential setting, in the client’s own home or in a mixture of the two. Standard 5 ought to apply to Transition Care and STRC services when they are delivered in a residential setting, but not when they are delivered in the client’s own home. This is consistent with the current approach and will be practical for service providers to manage.

Specific suggestions about each draft standard

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
It is positive to see that this standard recognises the need for ongoing assessment and planning for care and services. However, Requirement 2.3 states that services must be “continuously monitored and evaluated". As well as being highly subjective, the word “continuously” has the potential to create unrealistic expectations. Other terms such as “regularly monitored” or “timely monitoring” would be more appropriate.

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
Draft Standard 3 has a strong emphasis on physical and clinical care but does not acknowledge the mental health of residents and clients. The Draft Standard should be modified by adding in a specific reference to mental health. An appropriate place to include a reference to mental health would be in Requirement 3.2: “…optimises the service user’s physical and mental health and wellbeing”. The reference to ‘best practice’ clinical care in Requirement 3.2 incorrectly assumes there is a single correct way to provide various forms of clinical care, when in fact there may be more than one valid approach that is supported by evidence. Innovative approaches and the emergence of new evidence means that opinions on best practice may change. Given this, the term “evidence-based practice” would be more appropriate. The decision to list particular “high-prevalence” or “high-impact” risks in Requirement 3.7 will produce unintended, adverse consequences for consumers. Listing specific risks will elevate them above those risks that are not mentioned, skewing care provision and placing disproportionate emphasis on monitoring and managing the risks that are listed. For example, the focus on choking and falls will inevitably lead to an over-reliance on foods with modified textures and an increase in restraint. Surprisingly, in providing a rationale for including falls, the consultation paper mentions the need to minimise the risk of and harm caused by falls, but neglects any mention of consumer autonomy or choice which supposedly lie at the heart of the draft standards. The Consultation paper notes that no list of high-prevalence, high-impact risks will ever be exhaustive. Yet it will be all but impossible to achieve consensus on which risks to include in such a list. The rationale for each of the risks listed states that organisations providing clinical care would need to have strategies in place to manage the listed risk. Yet there are several other clinical risks that require strategies from aged care organisations. While the standards encourage the use of evidence in clinical care, the evidence provided for selecting the high-prevalence, high-impact risks that are listed is inconsistent and tenuous. An eclectic selection of references is used to support the inclusion of some of the high-prevalence, high-impact risks, while others, such as choking, pain management and malnutrition/dehydration are not supported by any evidence at all. In addition, the detailed focus on clinical risk, contrasts with the lack of a list of risks relating to lifestyle and emotional wellbeing. Even though Standard 4 does not list any lifestyle risks, it is not deemed inadequate as a result. This inconsistency is perplexing when the Consultation Paper talks repeatedly about improving quality of life. The decision to list certain risks also goes against the general tone of the draft standards, which are outcome based rather than prescriptive. For example, Requirement 8.3.c talks about the approach to risk management in relation to organisational governance, but it does not include a list of specific high-prevalence, high-impact risks that will impact on consumers or the provision of care and services. It also goes against the regulatory research, which broadly affirms an outcome based approach. As a leading international comparative study on aged care regulation notes (Braithwaite J, Makkai T, Braithwaite V, 2007. Regulating Aged Care: Ritualism and the New Pyramid, Edward Elgar Publishing, Cheltenham UK, p.230): “The pursuit of precision, either by protocols or by the proliferation of ever-narrower rules, causes an unreliability that is a symptom of a deeper and many-sided malaise of regulatory failure. This is especially depressing since the pursuit of precision usually fails in its own terms – it fails to deliver precision.” A better approach would be to acknowledge, as the rationale in the consultation paper does, that different service users have different clinical and personal needs and that aged care services should understand the high-prevalence, high-impact risks for each service user, whatever they may be. As well as embracing a person centred approach, this would be more consistent with the rest of the standards, while reducing the risk of the unintended consequences of disproportionately elevating certain risks above others. At the same time, by not highlighting certain high-prevalence, high-impact risks, this approach would truly be comprehensive and exhaustive. Requirement 3.8 with its focus on antimicrobial stewardship does not belong in the aged care standards. It is true that aged care services should have an increased awareness of antibiotics and antimicrobial-resistant medications, but the aged care standards are not designed to be a vehicle for raising awareness about such issues. Aged care providers should adopt care strategies to minimise the need for antibiotics and dedicated campaigns should be delivered to reinforce this message, rather than including them in the standards.

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
Draft Standard 4 is well written and Requirement 4.2 in particular contains good principles.

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
Requirement 5.2 in its current form states that providers will be assessed on the “design and layout” of a service. HammondCare recommends that this requirement be modified with a focus on “maintenance and improvement of the environment to optimise independence, interaction and function”.

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
6.1 The organisation uses an effective overarching feedback and complaints resolution which ensures: a. Regular feedback is sought from consumers, carers, the workforce and others about their experiences of the service. b. Consumers, carers and others are encouraged and supported to make complaints, provide feedback and access advocacy services, language services and other mechanisms for resolving complaints. c. The workforce is supported to recognise, report and appropriately respond to complaints. d. Systems are in place to ensure information from feedback and complaints is used to drive continuous improvement in the quality of care and services.

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
Requirement 7.2.b mentions states that each staff member has the “qualifications” needed to perform their role effectively. At the moment, not all employees in an aged care service are required to have a particular qualification in order to perform their role. We feel that the inclusion of that term in the standards may establish new expectations around minimum staff qualifications, which would raise the barrier for entry to work in aged care without necessarily improving the quality of care. The fact that this standard also applies to volunteers raises further issues about mandated training requirements for volunteers. We recommend that the words “skills” and “capabilities” remain but “qualifications” be removed from this requirement.