Response 210697936

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

2. What is your name?

Name (Required)
Dr Khalil Sukkar

4. What is your organisation’s name?

Organisation (Required)
Not applicable

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
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
Please select one item
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
Please select one item
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
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
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
1) The consumer are engaging with established service providers who have been operating residential aged care for a number of years and potentially been through a number of accreditation audits.
2) There is a fair distribution of beds on offer across rasa and regions ensured by the area-locked bed licences released annually.
Strengths of current arrangements for providers
The current bed-licences allocated to the service provider:
1) aide in obtaining necessary funds from financial institutions
2) add to the value of the service provider
3) assist in budgeting and somehow forecasting return on investment
4) assist in workforce planning

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
-The current arrangement somehow create a monopoly-like for service to provided by a few providers
- There is a limited avenue or need for innovation for the industry to improve the services, building designs and operations
- There is a limited need/ demand to have transparent workforce allocation and staff development
Other issues with current arrangements for providers
Already covered in the paper
Are these problems occurring at national level, or only in certain areas (e.g. rural, regional and remote areas) or for particular consumer groups?
- There is a limited avenue or need for innovation for the industry to improve the services, building designs and operations to suit rural, regional and remote areas
What evidence supports your view that these are significant issues which need to be addressed?
-Anecdotal:
1) I have been operating residential aged care facilities for 23 years during which I have seen limited/no innovative operational systems/ processes to suit the changes in clientele, staff and contemporary practice
2) There is no demands/ needs to operate a fair and efficient service due to the limited number of service providers

Other factors caused by the current allocation arrangements:

1) limited players/ limited funds to develop & build more services, hence
a) Extensive borrowing by existing providers leading to stringent/ unrealistic return on investment with drastic effects on staffing and services
b) cuts in workforce development and over dependence on ineffective staff development processes leading to substandard care (as identified by the Royal Commission)

Design principles for alternative allocation models

9. Are the proposed design principles appropriate?

Please select one item
Yes
No
Please elaborate on your response
I believe model 2 is better suited to support the RC in its future challenges for the following reasons:

1) invites more investors in the industry
2) creates a real market with associated competitive advantage challenges targeting not only the customer but also the workforce
3) requires innovative designs and operational processes
4) demands drastic operational changes within the existing service providers
5) with a number of safe guards, provides better facilities, services, and workforce
5) eliminates the need to address parked licences

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

Please select one item
Yes
No
Please elaborate on your response
for option 2;

1) Strengthen regulatory compliance to absorb potential influx of inexperienced service providers (including commissioning and regular inspections)
2) Re establish the requirements to report on key personnel changes and experience
3) adopt some flexibility when inspecting for compliance with providers/ facilities of providing innovative designs and operational processes.

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

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

For the service providers: Improving the ACAR allocation would certainly improve flexibility for the service providers as It will assist in moving the licences and directing the investment where there is demand.
Although there is more benefit for the consumers in terms of availability of more beds on offer, I see a little benefit on the quality of beds provided.

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?
Unless the investors detect an increase in demand worth investing (which meets their business model) little or no increase in supply will occur.
for consumers from vulnerable cohorts (such as Special Needs Groups, consumers with dementia)?
No benefit as too small cohort / too specialised for the current players.

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

No for this model.

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
I believe model two would meet such changes
Other key changes to places management
No

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?

I believe this model will have little impact on the consumer though I believe this model could put negative pressures on my organisation.

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

I believe model 1 will have little impact on the industry as it will drive little change. In my opinion the industry has been and will continue to adopt a reactive approach to change strategically and operationally.

In my opinion, the current ACAR allocation has created complacency on behalf of the service providers. Demands and supply rules can have little effects with such model.

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?

I believe this model (1) will have little impact on the above as there is no real changes to the status quo.

Forcing service providers who ae not ready to build will, although improve supply, it could put huge operational and financial pressures on the providers with negative effects on the consumers and the workforce.

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?

I believe the only valuable improvement on model one is to relax the ACAR allocation so that more players /service providers enter the market. i.e. increase competition.
What steps/sequencing and timeframes would be appropriate to facilitate a smooth transition?
Give the industry 2 years before introducing the changes.
What specific supports or enablers would be required to ensure the changes are understood by all stakeholders and successfully implemented?
Explaining the changes and providing a one-off payment for the existing providers to engage/conduct a strategic planning exercise to prepare for the future changes.

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

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

I believe this model will have a number of benefits to residential aged care and will improve service, operational efficiency and availability.

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?

I believe a que will limit demand though will assist in ensuring commitment to receiving the service.

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)?

I believe date of approval has a little value, nevertheless, urgency (health and situational) need to be well thought and streamlined otherwise both the consumers and the industry will be negatively impacted.

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

nil

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

Support the validity period.

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?

Requesting an explanation/ rational to join and to re-join (if needed) . Stricter conditions could discourage genuine applicants.

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

Information provided by the services / aged care homes (checked for accuracy by the accreditation process) on the service provided, meals, staffing mix and levels, etc.

Developing avenue to educate the consumer on what to look for / how to search for services that suit their needs and finances.

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?

The market rules of supply and demand will ensure equitable access as there will be providers with different business models.

I would though recommend (limited) incentives and/ or subsidised fees for remote and minority groups.

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, I would adopt a different building model, a flexible staffing model and a tailored payment system (pay as you go).

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

I would review my existing portfolio to meet the new model; if my rooms can be refurbished economically I would do that other wise I would take out of service.
I will also negotiate with the staff a flexible staffing model especially with new recruits.
I will certainly need to improve my support services i.e. meals and hospitality.

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, absolutely.

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?

Most importantly, the new model will require:
1) competent management system and personnel.
2) Workforce redevelopment,
3) innovative/ flexible infrastructure that can accommodate pay as you need
and customers of a variety of financial abilities.

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?

Their operational model and the quality/ competence of the management team.

Liquidity / assets

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

Government regular release of information on potential needs/ demands in different areas (users/customers)

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?
Limited support ( as required) to service providers by the Government for areas with limited supply and high demand
for consumers from vulnerable cohorts (such as Special Needs Groups, consumers with dementia)?
as above

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

No conditions but incentives;

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?

Unless my organisation understands the demands of the new model, change its strategy, and invest in preparation for the new services required, it will be negatively impacted.

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

As in question 35.

Many will unnecessarily exit or incur large losses.

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?

As in question 35

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

No need to redistribute them as these will be part of the business model of the new providers i.e. one of the services provided.

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

Same as 38, extra services would or could be part of the services on offer depending on the their business / operational model.

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?

It can be term -related such as monthly repayments to encourage repayment with a grace period.

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?

Its hard to do the above though a gradual implementation can be the best safeguard.
What steps/sequencing and timeframes would be appropriate to facilitate a smooth transition?
2 to 4 years implementation period
What specific supports or enablers would be required to ensure the changes are understood by all stakeholders and successfully implemented?
Government can provide:
1) Information sessions on the changes and potential positive and negative impacts
2) Couching to the service providers on ways to adopt and embrace the changes.

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?

Aboslutely

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

No, I believe my comments above clearly shows my preference of an open market approach