Response 884514374

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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

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
Peak body - provider
Ticked Peak body - professional
Ticked Other - please specify below
Text box to add other roles
Professional/industrial association - union

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
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
Text box for suggestions about improving consumer outcomes
The ANMF supports the importance of the standards being consumer centered and believe it is essential that the consumers’ voice is a vital part of any quality assessment process. It is also essential that the consumer experience is combined with evidence that underpins how, and what, minimum care should be delivered in aged care. With this, informed consumers can make choices on their experience and care within the service they choose to accept. The consumer outcomes statements are reasonable.

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
We agree that a single set of standards to apply broadly to all approved providers is logical, it may not always be practicable to measure a residential aged care service to a community based service. Thus, the proposal that organisations only need to comply with the standard/s that effect their business is complex, as the Department will have to have very clear information on what the organisation is actually providing to consumers as their business model and all the information that they provide to potential and actual consumers of their business in order to know what they have told consumers (especially in a community setting) what they intend to provide. However, all standards for nursing care, whether provided in the residential or community setting must always meet the accepted professional standards set by the regulatory authority (NMBA) for nursing practice and this standard is never negotiable. Therefore, the ANMF espouses that the standards need to must provide clear and concise information about any specific requirements for compliance with and ensure that the standard is that are not open to interpretation by the approved provider and are always based on evidence. Currently, the draft standards in some areas are too broad and do not provide enough detail to enable them to be achievable for providers.

12. Are the draft standards measurable?

Please select one item
Yes, always
Yes, mostly
Ticked Yes, sometimes
No
Don't know
Text box - suggestions are draft standards measurable
There are a number of standards which could be measured, for example, quality standard 1. Consumer dignity, autonomy and choice. This can be measured by asking consumers directly. However, there are a number of standards which are not measurable, where the wording used is ambiguous and open to interpretation. For example in standard 7. Human resources, - how do you measure ‘considerate’ for example?7.1 sufficient workforce to deliver and manage safe and quality care services. The term ‘sufficient’ is not evidence based and is not measurable (refer to standard 7 for a solution of a measurable outcome for this standard). 7.3 the workforce is supported, trained and equipped to deliver the outcomes required by the standards; there must be a definition of what is meant by supported and by who the support is provided. Training has to mean nationally accredited training for VET level entry employees and for all registered health practitioners, registration with the Australian Health Practitioners Regulation Agency.

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 intent of the standards needs to be strengthened and made explicit. Standard 3 - should include an Advanced Care Directive to alert the provider to the consumers choices for care if their circumstances change during the clinical care episodes. Standard 5 - what happens where a consumer is at end of life and not able to know if they are having an enjoyable consumer experience as they are being palliated and on medication that induces coma? Standard 6 - how will the workforce be able to provide feedback - this must be made clear and steps put in place in the standard to ensure it is measurable. Standard 7 – Human Resources (should be organizational culture that is measured here). Standards 7.1 to 7.5 must contain criteria to benchmark against, and not left open to interpretation by organisations.

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

Please select one item
Yes, always
Yes, mostly
Ticked Yes, sometimes
No
Don't know
Text box for suggestions about how wording and intent could be improved
The intent of the standards is clear for majority of the content, however, as we have previously identified, using words which are ambiguous and open to interpretation is not helpful. The rationale and evidence statements, really need to be embedded in the standard to ensure the intent of the standard is maintained and not changed or interpreted differently by different providers and ensures a consistent standard across the entire sector.

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 draft standards are relevant to all service areas identified.

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
Standard 1 - is an important addition to the quality process. The ANMF Vic Branch is supportive of the importance of the standards being consumer centered and considers it is essential the informed consumer’s voice to be heard as part of any quality assessment process. In the rationale and evidence section under identity, culture and diversity we suggest following addition be made in bold: All aged care services are expected to deliver care that is culturally safe, non-discriminatory and inclusive…..

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
Overall this standard provides important requirements to ensure consumers are engaged within their assessment and planning. The ANMF suggest a number of additions. Consumer outcome I am a partner in the ongoing assessment and planning of my care and services The term ‘partner’ can be interpreted as suggesting the care being provided is in partnership with the consumer, therefore the provider is an equal participant in the care relationship. This is incorrect - the informed consumer should direct care not negotiate care requirements with an equal partner. In section 2.2 Assessment and planning, the ANMF believes this standard needs to clearly articulate who should be conducting the assessment and planning. The Australian Commission of Safety and Quality in Health Care national standards use the term ‘clinician’ and define this term in the glossary. The ANMF suggest this should be expanded, and clearly state ‘a Nurse Practitioner, Registered Nurse or Medical Practitioner’. It is essential these registered practitioners are identified as the only practitioners in the aged care sector to provide comprehensive assessment and planning. This position is supported by the evidence outlining how registered nurses positively affect consumer outcomes , , . There is also increasing evidence identifying the difference nurse practitioners are making in aged care and consumer outcomes , . In regard to item f, in section 2.2, that states includes advance care planning and end of life planning if the consumer wishes - this addition is supported by the ANMF and we suggest that this is completed on admission or close to admission in the aged care service. Statement 2.3 Care and services are implemented and continuously monitored and evaluated for effectiveness. It is important providers have policies and procedures in place outlining how this care is implemented to support the aged care workforce in delivering the quality outcomes required. The following should be added to 2.3 (additions are in bold): Care and services are implemented and continuously monitored and evaluated for effectiveness. Organisational policies and procedures are in place to support Nurse Practitioner, Registered Nurse or Medical Practitioner in providing quality assessment and planning.

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 separation of care into personal care and clinical care is intertwined and only needs to be distinguished by the fact that a client/consumer must be first assessed by a registered nurse to develop a nursing care plan that incorporates both personal and clinical care. After the nursing assessment has been conducted the registered nurse can then determine the level of care that is required for each individual and such care can then be planned and where appropriate delegated to a person other than a registered nurse. Care for a consumer needs to be holistic in its approach in order to provide quality care. Using the statements provided, both personal care and clinical care require the informed consumer to direct their care that is appropriate and delivered by the right clinician. The statement regarding clinical care has the addition of best practice. It is incorrect to presume best practice is not delivered in personal care. The ANMF (Vic Branch)is supportive of the inclusion of best practice and considers the statement 'where evidence is available', ought to be relied on to inform the provision of best practice is an important addition to the standards. In the point 'unexpected deterioration or change', it is essential there is reference made to the clinician providing the care of identifying and responding to unexpected deterioration or change and it is stated this clinician is appropriately qualified and is a registered health practitioner. We strongly recommend the inclusion of the words 'registered nurses' and 'enrolled nurses' in this section. Surveillance and data collection is required to be added to the item 'identification' and 'management of high-impact or high-prevalence risks to the consumer'. It is crucial these high-impact and high-prevalence risks are tracked and that the data is analysed and evaluated to improve consumer outcomes. In the last paragraph of the rationale and evidence section it states we acknowledge that, ultimately, medical practitioners are responsible for prescribing antimicrobials. Nurse Practitioners are also able and do prescribe antimicrobials and should be added into this sentence. An additional point needs to be added We suggest at 3.9: Systems are in place to support clinicians to deliver quality and comprehensive care. This addition is discussed in the Australian Commission of Safety and Quality in Health Care national standards and the ANMF believes it is a substantial addition to this standard to ensure providers support clinicians by providing appropriate systems and resources.

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 ANMF Vic Branch acknowledges that some areas of the private residential aged care workforce within the aged care services sector has experienced severe structural problems including but not limited to 'inadequate skills mix' and a 'lack of staffing numbers' to deliver the assessed clinical and personal care needs of residents/consumers. Nursing is legislated to assess, plan and co-ordinate care in accordance with the Aged Care Act 1997. This requires registered nurses to plan nursing care. Approved providers are required under the Aged Care Act 1997 and its principles to provide adequate numbers of care staff to carry out the assessed care needs. However, the Act is silent as to the number of nursing or unregulated care staff required to be sufficient to deliver assessed care needs. The fact that the Act is silent on staffing numbers has led to the current state of the private aged care workforce. Despite the very best efforts of those who work in the sector, there simply are not enough workers nor enough workers with higher level skills to provide quality care to all elderly Australians where a specified number of care staff has not been mandated in an industrial agreement between the union and the approved provider. Consequently, the lack of definition about what 'sufficient' means in the Act has prevented the Australian Aged Care Quality Agency from having the tools to enable them to effectively assess minimum staffing and skills mix, which has in turn exacerbated the workforce and quality care issues within the sector. The current standards are also silent, they are ambiguous and open to interpretation. There has not been an evidenced based solution to benchmark staffing and skills mix and therefore some have believed that terms such as ‘sufficient’ need to be used. As recently as 10 April 2017, the Minister for Aged Care Ken Wyatt acknowledged the need for the long-overdue aged care workforce strategy that provides a broad approach for workers in the sector. Specifically, in an interview with Inside Ageing, Minister Wyatt said he recognised the crucial importance of having “a ratio of nurses or a ratio of care givers” when developing a workforce strategy for aged care. The ANMF Vic Branch considers that Minister Wyatt’s comments came at a time when recent examples of chronic understaffing in nursing homes around the country were resulting in avoidable injuries for patients, that have a direct relationship to the number and skill of care staff. To highlight the this significance a of the issue, the ANMF commissioned a research project, looking at the National Aged Care Staffing and Skills Mix. The findings of that Project have been recently been released, and highlight the urgent need for a staffing and skills mix methodology that considers both staffing levels (the right number) and skills mix (the right qualification) for residential aged care is urgently required in Australia. The National Aged Care Staffing and Skills Mix Project showed that nursing home residents were receiving just on 2.84 hours of care each day, when they should be receiving over 4 hours and that a skills mix of Registered Nurses (RN) 30%, Enrolled Nurses (EN) 20% and Personal Care Worker (PCA) 50% was the minimum skills mix needed in nursing homes, therefore the ANMF Vic Branch believes the proposed new Standards of Human Resources must clearly reflect these findings. Additionally, the point under the rationale and evidence section is required and it should state the following: Clinical leadership: 24 hour presence of registered nurses is required at all residential facilities with one or more residents requiring high care. The definition of high care should be an ACFI score of C or greater in the ADL Domain and/or the Behaviour Domain and/or an ACFI score of B, C or D in the Complex Health Care Domain. The standard should also set out that all providers of aged care services must publically demonstrate transparency on the My Aged Care website as well as their own website/s to enable consumers and potential future employees to make informed choices about the level of service provision and their usual staffing levels per resident and the skills mix of those staff, including nurses and carers. An amendment is required under the section titled 'the attributes and performance of the workforce', specifically in the paragraph under the National Regulation and Accreditation Scheme (NRAS), as it is incorrect to state that NRAS does not address the attributes and attitude of the organisation’s workforce; and the way in which members of the workforce interact with consumers. The National Boards, including the Nursing and Midwifery Board of Australia under the NRAS scheme, have a code of conduct and code of ethics which regulate health practitioners such as nurses and doctors in the way they interact with consumers.

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
Use of electronic health and health care records ought to be included in this section to incorporate the Commonwealth government's commitment to digital health nationally.

Other Comments

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

Text box - any other comments or suggestions
The ANMF Victorian Branch welcomes the opportunity to participate in further iterations of the Standards and any consultation in relation to the development of supportive materials.