Response 155625814

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Before your start, please advise your consent to publish response

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)
Ticked Publish response, but keep my name private (include my organisation's name)
Publish response anonymously (remove both my name and organisation's name)
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Before you start, please tell us about yourself

4. What is your organisation’s name?

Organisation (Required)
Lifecare

5. What stakeholder category do you most identify with?

Please select all that apply
(Required)
Consumer
Carer or other consumer representative
Consumer advocacy organisation
Consumer peak body
Carer peak body
Ticked Approved provider of residential aged care
Ticked Approved provider of flexible aged care
Ticked Approved provider of home care
Aged care provider peak body
Ticked 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
Ticked Not applicable
Please select one item
Ticked not-for-profit
for-profit
government
Please select one item
operating a single aged care home only
Ticked operating 2 to 6 aged care homes
operating 7 to 19 aged care homes
operating 20 or more aged care homes
Please select one item
specialising in servicing particular consumer group/s
Ticked providing generalist services
Please select one item
Ticked 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?

Please select all that apply
(Required)
New South Wales
Australian Capital Territory
Victoria
Queensland
Ticked South Australia
Western Australia
Northern Territory
Tasmania
All states and territories in Australia
Please select all that apply
(Required)
In a remote area
In a rural area
In a regional area
Ticked 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
Local input into the quality and capacity of the provider to deliver. This was even better when each Jurisdiction had their own ACPAC-Aged Care Planning Advisory Committee.

Strengths of current arrangements for providers
Able to indicate a good understanding of need and unique dynamics of local areas where particular issues.e.g dementia might need extra support.

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
Rural remote and CALD and single service providers are prejudiced by a system that rewards the most professional and articulate applications.

There is a industry for contractors to apply for fee for service a rudimentary analysis of applications would reveal a high level of cut and paste and formularised appliactions.
Other issues with current arrangements for providers
Spatial equity is not well addressed in the current system. When this system was introduced it was overlayed over a mal distribution of places particularly in the eastern suburbs of Sydney Melbourne and Adelaide. This mal distribution has continued to impact on the number of new places available to a jurisdiction even if their resources are concentrated into one area and not providing access more broadly.
Further this mal distribution has further been used to justify a smaller allocation of home care packages into SA in particular where we are supposedly over bedded with residential . The Government continues to look at the combined provision of resi and HCP in the Report on Government services even after the HCP are no longer distributed according to any regard for spatial equity. Hence SA is deemed over bedded (even if this is a historical legacy) and this has seriously impacted in the allocation of packages in SA where we are well below a per capita rate.
Are these problems occurring at national level, or only in certain areas (e.g. rural, regional and remote areas) or for particular consumer groups?
Rural Remote Cald and single service providers are all over represented in those services tat are less financially viable (see Stewart Brown) yet a high proportion of new places go to For profits who do not provide for these groups in the main.

In SA in the round before last Golden Grove was the Only SLA that was deemed a priority in the ACAR planning documentation However no places were allocated as an exisiting provider moved places to the area just prior to ACAR yet other providers were not aware that the only priority area would not be supported-This indicates a difficulty where providers are applying for what may not be available

Market failure will continue in areas where there are 50% of providers making a loss, years of trying to get ACAR applications in these areas with various strategies has been unsuccessful
What evidence supports your view that these are significant issues which need to be addressed?
A disproportionate number of small rural facilities have encountered compliance issues and are also prominent in those making a loss (see StewartBrown) yet we expect these small organisations to compete with the large for profits and not for profits who have teams to write their ACAR applications or use expensive consultants.

The Aboriginal Flexi model might provide a better approach for increasing availability of care in these regions rather than the current ACAR.

Design principles for alternative allocation models

9. Are the proposed design principles appropriate?

Please select one item
Ticked Yes
No
Please elaborate on your response
History has indicated that the market is non existent for some rural and remote regions

The existence of available aged care, the existence of a local health service the presence of a doctor and the communities viability can all be tied together in communities with Ageing and declining populations . To lose the Aged care can have knock on consequences for the hospital and the doctor. Thus whatever allocation methodology is adopted in rural and remote will be better predicated on govt intervention than the effectiveness of Adam Smiths invisible hand.

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

Please select one item
Ticked Yes
No
Please elaborate on your response
Spatial equity across Australia

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

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

Views on model 1
Generally good however the market will follow profit and with any reduction in locational specificity we could see the continuation of larger numbers of aged care in areas with good existing provision.

There also needs to be a re-examination of the concept of permanent care increasingly timely capacity building and episodic support in a residential facility may be a more appropriate and a more contemporary approach

When providers go broke or are taken over I have seen the rules regarding where you can transfer places bent or ignored when there are viability issues and prudential concerns.

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?
Look at the flexi model where they may be funded for 20 but care for 15.

Financial incentives

Partnering up a group of small facilities in a region to reduce the purchasing training compliance costs
for consumers from vulnerable cohorts (such as Special Needs Groups, consumers with dementia)?
Dementia specific care stream needs to be developed then dementia places could be allocated to facilities that can demonstrate the capacity and design elements to provide good care. With the numbers coming through the system this should be a priority.

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
Limit the secondary market in places if an approved provider wins the places and doesn't need or want them any more they should go back to a central pool and be reallocated according to the existing area of highest need not sold for profit

Organisations who dip below accepted levels of performance should not be continued to be allocated places if the are non compliances in another state then this should impact on the applicants allocation.

For profit providers should be made to retain a higher level of liquidity if they apply for places. places were this year allocated to for profits that have such high debt gearing that if they fail it will have serious knock on for the industry as a whole. There should also be more significant consequences for large providers who demonstrate systemic failureRedacted text
Other key changes to places management
Clearer support and inclusion of TCP in the planning approach currently only unlicensed places can be used this enforced differentially in the different states.

There is currently a blurring of out of hospital in home and residential care with new options being available, maintaining the current approach limits how creative providers can be with vacant places.

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?

Model 1 potential impact
Much better for a larger proportion of metro seniors seeking residential aged care if providers have more flexibility but potential negative consequences in the current areas on market failure

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

Model 1 potential overall sector impact
The biggest concern in the sector is the seriously constrained profitability. If the current terms of trade continue how the places are allocated is irrelevant as there will be many more viability issues , currently the number of facilities up for sale is high and growing . Rural remote Cald are highly overrepresented in the group with compliance issues and market reforms or greater flexibility in setting the location will not change this.

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?

Model 1 & other programs or reforms
discussed above

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?

Model 1 implementation
Markets respond to demand but there will be demand in areas where it is profitable and demand in areas where it is not im unsure what is being proposed in areas of market failure that will change what currently occurs.
What steps/sequencing and timeframes would be appropriate to facilitate a smooth transition?
Change metro fist with sensible increased flexibility and keep a different system and quarantine a proportion for the areas and streams of care that are less attractive to providers.
What specific supports or enablers would be required to ensure the changes are understood by all stakeholders and successfully implemented?
Roadshow, webinar , info through the department communiques.

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

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

Model 2 views
If we want to replicate the wait list mess in HCP then this would do it. There is already considerable evidence to suggest the ACATs in different jurisdictions allocate priorities differently . eg for HCP level; 4 in SA less than 1/3 received a high priority but in NSW over a half did. While the state govt run ACATS remain the gate keeper and there is differential practice we will see spatial equity decline and where you live may well determine what you get not what you need.

The complex financial issues militate against the consumer and the provider being confident that what might be the consumers choice is also a good fit for the provider. Current terms of trade are such that any reduced discretion by the provider could impaxct viability

There could be inadvertent extra wait time and process that would see numerous prospective residents having to look at a third or fourth choice we could see a large number of eligible citizens in dire need wait longer to source a place.

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?

Model 2 views on queue
Just the creation of a queue can exacerbate wait times.
With 100,000 plus waiting for the right package it would not be long and a proportion of those who need a package will go from not getting a package to exceeding the dependency levels for package care amove from waiting for a package to waiting for a residential place . No government would want the continual reminder that older Australians are systematically excluded from any support..
We need to ensure that increased notional options does not translate into reduced real choice.

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)?

Model 2 views on date of approval and urgency
The ACATS in each state are very different in their approach SA only allocates a high priority to less than a third of their level 4 package recommendations where NSW its over half. Again the begnign assumption that the existing system returns fair outcomes needs challenging.

Date of Approval would also present difficulties. recently at the Royal Commission Redacted text Aboriginal Community Services in SA stated that there are about 50 Aboriginal Elders awaiting an ACAT on the remote APY lands and some have been waiting over a year.

Untill there is a single standardised national process where priority is standardised and fair these changes may just amplify the inefficiencies and inequities in the existing system.

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

Model 2 other prioritisation factors
Currently if your concessional or a bond payer impacts on the relative attractiveness of prospective residents . Some diagnosis are harder to find appropriate care. Some providers specialise in specific areas of care . Centerlink and Medicare-ACFI info often determine weather prospective residents are a good fit how these compatibilities are managed in the proposed process would determine if it can meet timeliness objectives.

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

Model 2 validity period of place
Acat assx can be taken up at any time . We don't wont to make people have repeated assx where it isn't necessary.

For some an ACAT approval for resi care is not taken up immediately and it would not be fair to force people into care prior to them electing to do so.

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?

Model 2 withdrawn place
I am uncomfortable with the perception that older people will cynically manipulate the system for their benefit. Not many people elect to enter Aged care prior to needing it and consumers need the option of choosing a service that is right for them not being turfed of the list for not taking the fist option etc.

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

Model 2 - Additional information or supports for consumers to select aged care home
They will probably need to continue to contact each prospective service like they do now to discuss the services care philosophy ancillary costs and charges, and vacancies available. Inspite of listings on my aged care these things can change several times in agiven day and no provider is going to be able to update my aged care in real time.

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?

Model 2 equitable access for particular consumers
Better differentiation of services that provide quality dementia care

A navigator or key worker dedicated to assist the consumer

Reviews from existing residents with similar needs on the quality of care they receive

Any serious compliance issues related to special needs care visable.

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?

Model 2 potential impact
As discussed above avoiding extra wait times in the system

The differential approach from ACATs around the country

The existing provision gaps -regional-specialist-cultural and to ensure the new approach addresses these not exacerbate them

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

Model 2 overall sector impact
There is a fundamental question here is the government prepared to have better market interventions in the existing areas of market failure or are they expecting more miracle's associated with the magic of the market that is hard to see currently.

Profitability is currently poor greater commerciality will mean winners and losers and it will be the rural remote cald and specialist care services that need more support.

Changing the allocation process may make metro residential care more viable but without significant government intervention with or without these changes the sector is marginally unattractive and the listed providers share price reflect limited market confidence with one assumes some of these long discussed reforms factored in.

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?

Model 2 impact on other programs or reforms
Timely movement from the acute care sector could be impacted by introducing new steps or processes.

The concerns over the future availability of capital to meet projected future demand will continue in this new approach

Non government regulated models may emerge because of the increased level of process and reduced viability.

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

Model 2 respite care
ON a per capita basis as is done oversees. or develop specific respite centres.

Respite TCP ,CAP ,episodic capacity building are all aspects of care that need to be incorporated into any future models. the notion that there is only a one way recipe for the future senior Australians is robbing older Australians opportunities for a better quality of life. Currently a high proportion of all those who receive TCP get to go home but only a small percentage get to receive this service. It should be offered to every one at the Acute Aged Care interface

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

Model 2 extra service status
It will remain as is I assume
The myriad of charging arrangements that exist reflect a spectrum of choices and budgets.
Im sure that people shouldn't pay for things hey cant benefit from but to deny consumers the opportunity to continue full citizenship by continuing to be able to make discretionary purchases is very important.

I think the world has moved on from the extra service non extra service dichotomy

Government should be cautious when limiting what consumers can and cant do

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?

Model 2 capital grants
Rigorous identification of areas where the market has failed and then with structured interventions develop regional plans with communities and providers that provide a road map of how in each of these regions or areas of specialist care there is a plan to ensure that where there are gaps or needs not being meet the Govt partner with Associations or individual providers to insure the future infrastructure and workforce capacity is bolstered through direct interventions.

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?

Model 2 implementation
We need to be honest here in the large part it will be family members that will need to undertake the majority of the info sourcing and navigation through the maze.

Currently the complexity of the system and the legal and financial requirements are onerous introducing changes that further articulate processes may improve this but most likely will introduce new layers of complex process.

Current feedback from the royal Commission is that MY Aged Care is complex and difficult particularly for ATSI and CALD consumers what is in this proposal that addresses this???
What steps/sequencing and timeframes would be appropriate to facilitate a smooth transition?
Industry consultation with the Peaks and COTA -ACFA-NACA etc

Staged implementation ensuring a step wise approach

Clear communicated shared view of the end state and its advantages
What specific supports or enablers would be required to ensure the changes are understood by all stakeholders and successfully implemented?
as above

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?

Other models to consider
Residential Care is the second Largest grudge purchase after your funeral .
Getting people to think about it little own plan for it has been historically unsuccessful.

A coordinated local community approach where providers and the community work together will important.

There is a danger that we are putting all this thought and energy into what many in the future may see as anachronistic. A didactic view of residential care as being the last place you go or somewhere from which you never return may be fostering a redundant attitude that itself needs to change. Retirement living with serviced appartments or package care being delivered with the opportunity for short term or end of life care is increasingly the international response to ageing. These proposed reforms don't step outside the prevailing conventional views of residential aged care

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

General comments
Redacted text . The local understanding from a regional- cultural perspective and the on the ground knowledge of what is working and not working was valuable information that was used to good effect.

With the current centralised process local understanding is not as prominent.

Over 200,000 older Australians call resi care home any changes need to address the complexity and difficulty many currently experience in accessing the right place.

We need an unequivocal view of the govt view of the substitutability of package care and residential care . On the one hand they are combined for the ROG report but packages are no longer allocated with any regard for spatial equity.
Do we have an integrated aged care system of a series of discreet programs that require navigation and even then you may not get what you need.