Residential aged care: Proposed alternative models for allocating places - Australian Government Department of Health

Response 136651904

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1. We would like your permission to publish your online survey responses to the discussion paper. Please indicate your publishing preference:

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Publish response (include both my name and organisation's name)

Publish response, but keep my name private (include my organisation's name)

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Before you start, please tell us about yourself

5. What stakeholder category do you most identify with?

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Consumer

Carer or other consumer representative

Consumer advocacy organisation

Consumer peak body

Carer peak body

Approved provider of residential aged care

Approved provider of flexible aged care

Approved provider of home care

Aged care provider peak body

Provider of private aged care or seniors accommodation

Aged Care Assessment Team/Service

Aged care worker

Health professional

Workforce association or union

Primary Health Network

State and territory government

Local council

Commonwealth agency

Lender or investor/financier

Other

Please select all that apply

people from Aboriginal and Torres Strait Islander communities

people from culturally and linguistically diverse backgrounds

veterans

people who live in rural or remote areas

people who are financially or socially disadvantaged

people who are homeless or at risk of becoming homeless

people who are care-leavers

parents separated from their children by forced adoption or removal

lesbian, gay, bisexual, transgender and intersex people

people with disabilities

people with dementia

other group

Prefer not to answer

Not applicable

Please select one item

not-for-profit

for-profit

government

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operating a single aged care home only

operating 2 to 6 aged care homes

operating 7 to 19 aged care homes

operating 20 or more aged care homes

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specialising in servicing particular consumer group/s

providing generalist services

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mostly offering single rooms with ensuites

mostly offering single rooms with shared bathrooms

mostly offering shared rooms with an ensuite

mostly offering shared rooms with common bathroom

mostly offering ‘other’ room type

6. Where does your organisation operate (if applicable)? Otherwise, where do you live?

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New South Wales

Australian Capital Territory

Victoria

Queensland

South Australia

Western Australia

Northern Territory

Tasmania

All states and territories in Australia

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In a remote area

In a rural area

In a regional area

In a metropolitan area or major city

Current arrangements

7. What works well under the current residential aged care allocation and places management model for consumers and/or providers?

Strengths of current arrangements for consumers

Limited.

Strengths of current arrangements for providers

Highly limited.

8. Are there other issue/s with the current model for the allocation and management of places for residential aged care that have not been covered in this paper?

Other issues with current arrangements for consumers

Unreliable outcomes for consumers, there is uncertainty if a provider believes they will get licences to create a new product. Then there is the uncertainty when granted if the provider will then enact the project. There was 1000s of licences issued but not in construction.

Other issues with current arrangements for providers

Infrequent
Costly to lodge an ACAR. Due to the irregularity of the process providers are encouraged to lodge multiple applications at one time in the 'hope' that something will get approved. Its more like a lottery than a well considered and timely process to support the provision of new care services in geographies requiring support and or revitalised product.
Outcomes have been highly irregular in the past.
Good projects are not being enacted do to the uncertainty of licence availability.
Secondary market has been created due to the lack of support from the department in providing licences / providing licences on a timely basis.
Historic issues where licences have been issued to providers in the past with no claim to the land. Claw back of licences that have not been enacted has historically been too slow, in recent period this has been seen to improve.

Are these problems occurring at national level, or only in certain areas (e.g. rural, regional and remote areas) or for particular consumer groups?

National

What evidence supports your view that these are significant issues which need to be addressed?

The fact there is a secondary market for licences issued at nil cost tells you all you need to know.
Significant amount of aged care stock that is not fit for future purpose due to monopolistic licence constraints to allow new product.
Significant number of licences issued but not being enacted. The process is creating a panicked void at ACAR time, over subscription without genuine knowledge if a part of that is because providers feel they need to roll the dice on multiple applications.

Design principles for alternative allocation models

9. Are the proposed design principles appropriate?

Please select one item

Yes

Please elaborate on your response

agree.

10. Are there any other principles that you consider should be included?

Please elaborate on your response

Negate the need or existence of a secondary market for licences.
Maybe to add the word TIMELY in the second bullet

Model 1: Improve the ACAR and places management - Overall model

11. What are your views on the suggested improvements proposed under this model?

Many benefits
It feels like it will be more timely which is good. The 'top up' idea for more beds in an established facility is a really smart touch.
We need strong rigor to reclaim licences so this is good and then if they could be reallocated out of cycle that would help. Generally if this options is done well, there should be an understanding that the department will issue xyz licences per annum, add to them licences that are reclaimed. The provider can then issue real time applications for licences and the department have like a council DA process, a real time allocation process.

Limitations is likely that the DOH will still look at macro supply and demand limitations rather than 'fit for purpose' and allow true market gentrification of the sector.

Model 1: Improve the ACAR and places management - Key design considerations

12. How can this model ensure/encourage adequate supply of and equitable access to residential aged care and residential respite care (aside from increasing funding or revising the funding model), including:

in rural, regional and remote areas and other thin markets?

The only way to solve this is to have relevant funding for provision of services in such a location.
Get the funding right and suddenly demand for licences in regional will present itself.

for consumers from vulnerable cohorts (such as Special Needs Groups, consumers with dementia)?

This is already considered in the approval process and will remain.

13. Are there variations to this model which should be included in the impact analysis?

Yes it should be real time application process, as noted earlier like a council DA.

14. What other key changes could be made to the existing ACAR and/or places management arrangements to encourage a more consumer driven and competitive residential aged care sector?

Other key changes to ACAR

More frequent
more transparent
Better informed about quality of stock in areas that are monopolised by tired old facilities.

Better understanding of what the department thinks it is seeking from Dementia. Its so misunderstood and mis funded. Its a real concern. Do the ACAR judging panel understand what to look for in an applicaiton? do they know if its actually enacted? Deregulate and the consumer will soon make their own choice.

Other key changes to places management

More frequent
more transparent
Better informed about quality of stock in areas that are monopolised by tired old facilities.

Model 1: Improve the ACAR and places management - Exploring the potential impacts

15. In overview, what would be the potential impact of this model (consider benefits, costs and risks) on you or the stakeholder group or organisation you represent?

Still too slow
Still seems to a big broad process where everyone fights to get all applications in at one time and there will still be hit and miss strategies.
Benefits have previously been highlighted.

16. What do you think might be the impact on the residential aged care sector overall?

Minor improvement.

17. If this model were to be implemented, what are the potential impacts on, linkages or interdependencies with, other programs or reforms in aged care that might impact you or the stakeholder group or organisation you represent?

Funding...................... if there is funding and licences, you will see the ongoing transformation of the quality of facilities, people employed and provision of this fundamental service to our amazing ageing population.

Model 1: Improve the ACAR and places management - Implementation and transition considerations

18. How could implementation of this model maximise the benefits and minimise risks/disruptions?

Covered earlier.

What steps/sequencing and timeframes would be appropriate to facilitate a smooth transition?

Seems like an immediate option with no risk.

What specific supports or enablers would be required to ensure the changes are understood by all stakeholders and successfully implemented?

Send a note that this is what you've done. Its not very complicated other than the real clarity about when licences will be reclaimed from inactive providers.

Model 2: Assign residential aged care places to consumers - Overall model

19. Overall, what are your views on this proposed model?

Revolutionary. In reality it is what the sector needs. It will shake the tree to ensure quality facilities and quality care models.
Realtime, real consumer choice and outcomes.
There are risks on Bond guarentee as some providers are so blase and entrenched they will not be able to adapt to competition coming.

Model 2: Assign residential aged care places to consumers - Key design considerations (consumers)

20. What are your views on the establishment of a queue to access subsidised residential aged care, if the demand from eligible persons exceeds the available places?

Isn't that what is already a risk with SRR now, how is it different?
Most of the population have the means to pay for care, they just dont want and feel its an entitlement, this can be realigned with time.
A number of older lower standard RACs will become 100% concessional and will be able to moderate this item that is already managed in the aged care society.

21. What are your views on using date of approval and urgency of need as factors in determining a person’s priority (noting these are the factors used in home care)?

ACAT is ACAT why would that change. The home care system is at best disfunctional. its a mess and its a danger to associate this proposed model too closely with home care.

22. What other factors should also be included in the criteria for prioritising a person in the residential aged care queue?

Need. Means. The market will figure the rest.

23. What are your views on the validity period of the assigned place for residential aged care?

Relevant as long as reassessments can be quick

24. Where a place is withdrawn, how can we balance the need to allow consumers to re-join the queue while also avoiding creation of perverse incentives for people to join the queue without intention of taking up a place at that time?

Whats the risk thats being managed? ACFI funding? Not clear how this directly relates to amending who the licences is managed by.

25. What additional information or supports would consumers need to assist them in selecting a preferred aged care home?

Access to the location, info in printed form and internet, like they have now..........

26. What would need to be in place to ensure equitable access to appropriate services when requesting entry to an aged care home i.e. in particular for consumers with limited capacity to pay, consumers from Special Needs Groups and those with dementia?

Knowing who provides low cost service
knowing who provides dementia care
no different to today.

Model 2: Assign residential aged care places to consumers - Key design considerations (providers)

27. As an existing approved provider: Would you consider changing your business, service or workforce model if these reforms proceeded? If so, how?

Yes we would build more where we see substandard product and good demographics.
We would ensure that our focus remains on quality care, brand, reputatoin and ensure that we can do the same in new locations.

28. As an existing approved provider: How would you ensure your aged care home/s remain competitive and attractive to consumers?

By working with the local community to ensure its needs and demands. Invest in required refurbishment

29. As a provider of private residential aged care or other seniors accommodation: Would you consider applying to become an approved provider under the Aged Care Act 1997 to offer subsidised care if these reforms proceeded?

Yes

30. What features in the model, or the broader system, would be required to support providers to operate sustainably in a competitive market? For example, how could innovation and differentiation in service and accommodation offerings be facilitated?

I think the market will work that out as long as there is still a barrier to entry being a high quality approved provider.

31. For those providers who are dependent on capital financing, what role does the ACAR system play in supporting their ability to obtain that financing?

ACAR is an impediment to financing, banks require 70% plus of bed licences to be secured before a project can commence. The fact that it is not run at regular intervals with any degree of certainty in an outcome, its a constraint to enacting the much needed development of new care homes to meet the growing demand that is only a few years away.

32. What might be required to ensure the residential aged care sector remains an attractive investment for financiers and lenders?

Ease of access. Time is very valuable to investment returns and investment sentiment. Linked with more deregulation to allow further user funded contribution to lifestyle activities/ hospitality and elements of care.

33. How can adequate availability of residential aged care services be supported (aside from increasing funding or revising the funding model):

in rural, regional and remote areas and other thin markets?

Funding is the obvious, entice people to provide. The market will work this out i think especially with such a heavy NFP missional support for the sector

for consumers from vulnerable cohorts (such as Special Needs Groups, consumers with dementia)?

Funding is the obvious, entice people to provide. The market will work this out i think especially with such a heavy NFP missional support for the sector

34. Is it possible to attach conditions to being an approved provider, and could these conditions be specific to locations or particular consumer groups?

Yes it is possible, conditions or incentives. Conditions would need consideration to ensure there is the right care focused outcome. Its not impossible to see an initial metric similar to the SRR to be mandated about an amount of care in regional or remote given the SRR ratio is no longer required as providers are incentivised to provide it.

Model 2: Assign residential aged care places to consumers - Exploring the potential impacts

35. What would be the overall potential impact of this model (consider benefits, costs, and risks) on you or the organisation or stakeholder group you represent?

Increased competition but that is healthy. Benefit would allow the chance to target areas of the country that have good demand and a below quality product, knowing you need to only buy the land and build the site and then bring your care model and you hope that consumers will find the service offering differentiated and interesting.

36. What do you think might be the impact on the residential aged care sector overall?

Enhancement of quality of assets and outcomes, matched with some providers struggling and exiting the sector. A form of consolidation will happen and a new form of smaller boutique care models will emerge.

37. If this model were to be implemented, what are the potential impacts on, linkages or interdependencies with, other programs or reforms in aged care that might impact you or the stakeholder group or organisation you represent?

Links very nicely to a co-located RV/Aged care model. In essence you don't need to move from your RV unit as the provider can move the funding to you in your RV unit. Internally a little home care but then full care. You create a building that allows ageing in place with multiple service levels, the staffing would adjust based on the cohort of residents, similar to low care / high care. Helps with considerations about the RV act and mandated buy back periods.

This reform would work very nicely with looking at unlocking funding via user pay and additional services. There will need to be a real variety in choice and pricing based on the unique living environment.

38. How could residential respite care places be distributed, and to whom, if residential aged care places no longer exist?

To the consumer. simple. the resident has a respite balance and goes to a provider to get respite. the market will have beds and take a mix of permanent and respite residents.

39. What are your views on how to manage extra service status under this model?

Better to clarify additional services and no requirement for extra services or make them all extra services. It will depend on the person and what they choose.
SRR should be done away with.

40. How might the allocation, eligibility criteria and/or administrative provisions (e.g. terms of repayment) for capital grants allocated through the ACAR need to change to best support the needs and objectives of a more market based model?

Will just be based on the business case and business model the provider puts forward for their new development - is it a good site, good location, good care - therefore it will have positive cashflows and it will be able to repay the grant.

Model 2: Assign residential aged care places to consumers - Implementation and transition considerations

41. How could implementation of this model maximise the benefits and minimise risks/disruptions?

Allowing the consumer to choose where they go, if the accreditation of quality of care is firmly maintained, that is low risk. But don't confuse (as this proposal doesn't) that this is about giving the resident the choice of how to spend the government funding like home care.

Ensure that ACATs and RAS are much quicker as there are delays at present that risk the proposed schemes. You need to leave the hospital knowing the funding is there for you.

What steps/sequencing and timeframes would be appropriate to facilitate a smooth transition?

Ensure that ACATs and RAS are much quicker as there are delays at present that risk the proposed schemes. You need to leave the hospital knowing the funding is there for you.

Have a support function for lazy providers who start having a call on bonds as the market determines that their product and service offering is out of date. Will take 3-5 years for this to really take place and with good monitoring of cashflows for providers it can be monitored.

What specific supports or enablers would be required to ensure the changes are understood by all stakeholders and successfully implemented?

Workshops and detailed instructions on the internet. A lot better internet support than MAC. More support for ACAT and RaS providers to act quickly. More quality assessors in place of ACAT assessors to ensure that any new providers are ensuring quality in care and resident outcomes.

General views

42. Aside from the two proposed models, how else could we encourage greater consumer choice and a more consumer driven market in residential aged care?

Residents and future residents are smart humans who have been independent most of their life, supporting a view that they can make more of their own choices, spend their own money will help improve aged care. We need to move the mindset of privilege and aged care being an entitlement / free. My grandparents pay less for 24 hour care support, accommodation and food than i pay for my children to have 6 hours of support and one meal at day care, how can that work? Its because child care is free market and aged care is government micro managed.

Maintain the gov funding and support for care and create a minimum payment for supported resident basic daily fees and accommodation, but otherwise allow an open market. Support clarity and empowerment for additional services.
Maintain high standards of accreditation to ensure that only the best carers survive but otherwise don't prolong the Mike Baird esq lock out laws Nanny state mentality.

If the licences are opened up, there will be gentrification of product. If the funding is opened to user pay, then service models will follow that are viable and relevant to consumer choice. Gov maintain a view of care support and standards and focus on viable funding for regional and less affluent communities.

43. Do you have any other overall comments you wish to provide?

The format of this website is not user friendly clicking in out of screen. Simple concise flow would help. A number of items are very similar in their nature.

Please do all you can to support clarity in this process and accelerate this process as its been stagnant for far too long.