Response 942807100

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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
LeapFrog PL

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
Aged care worker/professional
Aged care advocate
Peak body - consumer
Ticked Peak body - provider
Peak body - professional
Ticked Other - please specify below
Text box to add other roles
Residential Aged Care Quality Consultant

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
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
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
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
Ticked Yes, always
Yes, mostly
Yes, sometimes
No
Don't know
Text box for suggestions about improving consumer outcomes
The standards reflect key matters that are important to consumers and their family members in all aspects of care and service delivery. The standards will facilitate the implementation of person-centered care rather than the task-oriented care that is predominantly provided in residential aged care. As a consumer with my father-in-law passing away in aged care and a much loved Aunt currently in aged care I know what it is like for both the resident and family to be dis-empowered and not have real input into the development of individualised goal setting and care provision. And also to be concerned that staff do not have the knowledge to provide safe and quality care and services in a respectful manner.

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

Please select one item
Ticked Yes, always
Yes, mostly
Yes, sometimes
No
Don't know
Suggestions - are organisational statements and requirements achievable
The standards will only be achievable if organisations are committed to and able to implement person-centered care. To do so will require transactional leadership to move from rigid structures and task-oriented work to support and empower people (staff) to engage with consumers and have the capacity and confidence to make decisions in partnership with the consumer on a day to day basis. Most residential aged care management approaches use a hierarchical approach with a rigid task-oriented routine which dis-empowers people (staff) and reduces consumers' choice and enjoyment of life. It is recommended that the resource material include information about consumer-centered care and leadership. Another consideration is that the ACFI encourages providers to provide full assistance to residents to maximise funding. Therefore supporting consumer independence and autonomy (St 1) to achieve the standards is not congruent with maximising ACFI funding to enable providers to provide care. A transition to Consumer Directed Care in residential aged care would assist to implement the standards without being influenced by the funding model.

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
It will be challenging to measure the outcomes for consumers who do not have a voice due to frailty and without a representative.

13. Are there any gaps in the draft standards? If so, what are they?

Please select one item
Yes
Ticked No
Text Box for gaps in draft standards
The standards cover the key matters for consumers as well as clinical best practice and; corporate and clinical governance that are not clearly articulated in the current residential aged care standards. This said, there have been comments from residential aged care managers stating that they are concerned that if specific aspects of care e.g. behaviour management, continence management, sleep and rest, oral and dental care that are in the current residential aged care standards are not included these areas of care may not be addressed. My view is that the inclusion of the requirement of 3.2 to demonstrate that clinical care is best practice and the requirement 8.4 c requiring the provision of integrated corporate and clinical governance and leadership will address this concern. It is recommended that the resource material is clear about the

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
It is recommended that the resource material provide increased clarity that whilst the standards set out the core expectations for the safety and quality of care and services for consumers organisations will still need to comply with relevant legislative requirements, standards and guidelines as stated in 8.3 a . This would include requirements that are included in the current residential aged care standards e.g. fire and other emergencies, health and safety, contract management of external services, privacy.

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
It is my view that all are relevant to residential aged care.

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
No specific suggestions

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
During the Department's webinar on 29 March 2017 there was a suggestion by a viewer that Standard 2 and 3 are duplicated and should be combined. I disagree and believe that they are two discrete aspects of care with standard 2 addressing the engagement with and planning in partnership with the consumer about their needs and preferences. Whilst standard 3 is related to the delivery of services. Therefore it is my view they should be separate to highlight the importance for consumer engagement. Quality Assessors would most likely assess how engagement and planning in partnership occurred (St 2) and then assess if the care is being delivered according to the plan (St 3).

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
See Q17 It is recommended that the resource material provide some clarity around the expectations of handover in a residential aged care organisation. It is recommended that physical and chemical restraint be included in the Rationale and evidence section. Please clarify the relevance of the standards and the Residential Aged Care National Quality Indicator Programme.

Other Comments

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

Text box - any other comments or suggestions
It is my view that you have got the balance right in relation to refocusing the standards on consumer outcomes instead of an organisation's systems and processes. Organisations will still need to have systems and processes and continuous improvement activities in place to achieve regulatory compliance, best practice and the standards however it is understood the Quality Agency assessment will focus on whether the organisation is achieving the consumer outcomes. Well done!!