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:
Please select one item
(Required)
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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Publish response anonymously (remove both my name and organisation's name)
Do not publish response
Before you start, please tell us about yourself
5. What stakeholder category do you most identify with?
Please select all that apply
(Required)
Consumer
Ticked
Carer or other consumer representative
Consumer advocacy organisation
Consumer peak body
Carer peak body
Ticked
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
Ticked
Other
If you answered ‘Other’, please specify:
As a firm of Chartered Accountants, we assist several stakeholders in relation to aged care. We regularly assist clients whose family members need residential aged care and who turn to us for assistance in navigating the process and understanding the costs. Additionally, we have been a key adviser to an approved provider of residential aged care for over 20 years and have a thorough understanding of the operation of the ACAR round, having participated in several such applications by our client. We are also currently applying for approved provider status for a new entity that will provide residential aged care. Finally, as taxpayers, we have a vested interest in ensuring that scarce Government resources are wisely and efficiently spent.
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
not-for-profit
Ticked
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)
Ticked
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
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
• Residents have a strong bargaining position as providers need residents to fill available places.
• Any resident who has been assessed by ACAT as being eligible for residential care may seek and take up an available place at a time of their choosing.
• Places are available in all locations (not just those considered to be more financially attractive for providers) resulting in prospective residents having access to places in their local area.
• Consumers are not involved in the allocation of places so they do not need to be involved in it.
• Any resident who has been assessed by ACAT as being eligible for residential care may seek and take up an available place at a time of their choosing.
• Places are available in all locations (not just those considered to be more financially attractive for providers) resulting in prospective residents having access to places in their local area.
• Consumers are not involved in the allocation of places so they do not need to be involved in it.
Strengths of current arrangements for providers
• As the number of available places in an area is somewhat regulated, there is some level of certainty for Approved Providers.
• The over-supply of places in some areas and under-supply in others is somewhat regulated as the Department controls the issue of new licences.
• The over-supply of places in some areas and under-supply in others is somewhat regulated as the Department controls the issue of new licences.
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 system works well for consumers as they do not need to be involved in it.
Other issues with current arrangements for providers
• The ACAR round occurs irregularly – the timing is unpredictable
• Success or failure of an ACAR round application is unpredictable
• Failure of an applicant to obtain the required licences means waiting for the next round, which could mean waiting for up to 2 years or purchasing bed licences in the market at significant cost (around $75,000 per bed licence)
• Success or failure of an ACAR round application is unpredictable
• Failure of an applicant to obtain the required licences means waiting for the next round, which could mean waiting for up to 2 years or purchasing bed licences in the market at significant cost (around $75,000 per bed licence)
Are these problems occurring at national level, or only in certain areas (e.g. rural, regional and remote areas) or for particular consumer groups?
As the ACAR process is a national process, I expect that these issues are occurring nationally.
What evidence supports your view that these are significant issues which need to be addressed?
• It was stated in the consultation session that in the last ACAR, applications were received for 37,802 places but only 13,500 places were allocated
• Licences are trading in the market at significant cost (around $75,000 per bed licence)
• Licences are trading in the market at significant cost (around $75,000 per bed licence)
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
The design principles are appropriate.
10. Are there any other principles that you consider should be included?
Please select one item
Ticked
Yes
No
Please elaborate on your response
Additional design principle should include:
• Simplifying (or at the very least, not adding to) the process by which consumers access residential aged care
• Reducing the barriers to entry of new providers and the expansion of smaller existing providers
• Reducing the number of 'inactive' allocated places
• Improve the integrity of the bed licences to ensure that they are used for their intended purpose (and not used as a commodity to be traded)
• Simplifying (or at the very least, not adding to) the process by which consumers access residential aged care
• Reducing the barriers to entry of new providers and the expansion of smaller existing providers
• Reducing the number of 'inactive' allocated places
• Improve the integrity of the bed licences to ensure that they are used for their intended purpose (and not used as a commodity to be traded)
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
• The locational controls are very important. and any further dismantling of this process should be avoided.
The 2018-19 ACAR map shows those there are many areas that are 'over-bedded' and many that are 'under-bedded'. Anecdotally, it appears that the over-bedded areas correspond with more affluent areas and under-bedded, with lower socio-economic areas.
I expect that reducing locational controls on the allocation of places will result in providers targeting the more affluent areas in an effort to gain access to the higher resident fees that might be available in those areas. Whilst this will be good for competition in these area and will most likely drive down costs in those areas, the less affluent areas could well be relatively neglected, resulting in less competition and higher resident costs in these areas.
When Government resources are limited, targeting of services by Government to ensure that services are available to local communities is important.
• The transfer of residential aged care places should NOT be permitted.
Allowing places to be transferred has created a market in aged care places in which the places are now a commodity. When coupled with the scarcity of supply of new places, this market creates a barrier to entry of new providers and to the expansion of smaller existing providers, ultimately reducing competition and artificially inflating costs for the taxpayer and residents.
The 2018-19 ACAR map shows those there are many areas that are 'over-bedded' and many that are 'under-bedded'. Anecdotally, it appears that the over-bedded areas correspond with more affluent areas and under-bedded, with lower socio-economic areas.
I expect that reducing locational controls on the allocation of places will result in providers targeting the more affluent areas in an effort to gain access to the higher resident fees that might be available in those areas. Whilst this will be good for competition in these area and will most likely drive down costs in those areas, the less affluent areas could well be relatively neglected, resulting in less competition and higher resident costs in these areas.
When Government resources are limited, targeting of services by Government to ensure that services are available to local communities is important.
• The transfer of residential aged care places should NOT be permitted.
Allowing places to be transferred has created a market in aged care places in which the places are now a commodity. When coupled with the scarcity of supply of new places, this market creates a barrier to entry of new providers and to the expansion of smaller existing providers, ultimately reducing competition and artificially inflating costs for the taxpayer and residents.
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 ACPR system provided a greater ability for the Department to target places to areas that are relatively 'under-bedded'.
for consumers from vulnerable cohorts (such as Special Needs Groups, consumers with dementia)?
Disallow the transfer of places between providers and regions.
Introduce a system that encourages providers to relinquish inactive places.
Introduce a system of more regular (or even continuous) assessment of Aged Care Place Applications.
Introduce a system that encourages providers to relinquish inactive places.
Introduce a system of more regular (or even continuous) assessment of Aged Care Place Applications.
13. Are there variations to this model which should be included in the impact analysis?
Model 1 variants
Yes.
In addition to Leaving licencing of places with Approved Providers:
• Discontinue the ability to transfer licences from one Approved Provider to another or from one location to another
• Replace/supplement the ACAR with a continuous allocation process
• Introduce a Bed Licence Charge and an Occupied Bed Incentive Payment for providers
These matters are detailed in the attached document.
In addition to Leaving licencing of places with Approved Providers:
• Discontinue the ability to transfer licences from one Approved Provider to another or from one location to another
• Replace/supplement the ACAR with a continuous allocation process
• Introduce a Bed Licence Charge and an Occupied Bed Incentive Payment for providers
These matters are detailed in the attached document.
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
As the discussion paper notes, occupancy throughout the sector is currrently running at 94.3% of available places.
The main way in which consumer choice will be improved is if more places are available for consumers to choose from.
The main way in which consumer choice will be improved is if more places are available for consumers to choose from.
Other key changes to places management
• Leave the licencing of places with Approved Providers
• Discontinue the ability to transfer licences from one Approved Provider to another or from one location to another
• Replace/supplement the ACAR with a continuous allocation process
• Introduce a Bed Licence Charge and an Occupied Bed Incentive Payment for providers
These matters are detailed in the attached document.
• Discontinue the ability to transfer licences from one Approved Provider to another or from one location to another
• Replace/supplement the ACAR with a continuous allocation process
• Introduce a Bed Licence Charge and an Occupied Bed Incentive Payment for providers
These matters are detailed in the attached document.
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
The current system of allocating places does not place any burden on consumers. Changing it to allocate licenced places to consumers will place an additional burden on already over-burdened consumers.
16. What do you think might be the impact on the residential aged care sector overall?
Model 1 potential overall sector impact
The residential aged care sector works well but could use some improvement. Please see our response to question 14.
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
Please see our response to question 14.
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
Our propoal could be implemented relatively quickly.
Model 2: Assign residential aged care places to consumers - Overall model
19. Overall, what are your views on this proposed model?
Model 2 views
Under the current system, for a consumer to enter residential care they must navigate the following processes:
1. They need to learn about a very complicated system
2. They must be set up with a My Aged Care record
3. They must be assessed by the Aged Care Assessment Team as being eligible for residential care
4. They must complete and submit a means test application to the Department of Human Services
5. They need to research the available homes
6. They must source an available place
7. They need to be offered a place
8. They need to move to the home
The process is usually carried out by a family member of the intended care recipient. Having dealt with countless families in relation to this process, one point is clear: every family finds this process extremely difficult and emotionally draining, principally because they are dealing with a personally difficult task (finding a place for their loved one in a residential care facility). Most have described this task as being the most difficult thing they have ever had to do. All described the process as being horrible!
The proposal is to add an additional step after step 3 and before step 5 of the above ‘horrible’ process: to arrange for the consumer to be put on a waiting list (presumably administered by the Department) and to await their turn to be ‘eligible’ to seek an available place.
Requiring prospective residents to enter a ‘waiting list’ will add a level of complexity for the resident’s family and make entry into the RAC system more difficult. It will also restrict access to those residents who are deemed ‘most needy’ by the department and force others to wait.
It is our view that every person who has been assessed by the ACAT as being eligible for RAC should have the immediate and unfettered ability to source an available residential care place. No one should have to wait until the Department (or someone else) allocates them a licence.
Rather than providing improved access to residential care, this proposal will make the process more difficult and may in fact affect consumers’ access to residential care adversely.
1. They need to learn about a very complicated system
2. They must be set up with a My Aged Care record
3. They must be assessed by the Aged Care Assessment Team as being eligible for residential care
4. They must complete and submit a means test application to the Department of Human Services
5. They need to research the available homes
6. They must source an available place
7. They need to be offered a place
8. They need to move to the home
The process is usually carried out by a family member of the intended care recipient. Having dealt with countless families in relation to this process, one point is clear: every family finds this process extremely difficult and emotionally draining, principally because they are dealing with a personally difficult task (finding a place for their loved one in a residential care facility). Most have described this task as being the most difficult thing they have ever had to do. All described the process as being horrible!
The proposal is to add an additional step after step 3 and before step 5 of the above ‘horrible’ process: to arrange for the consumer to be put on a waiting list (presumably administered by the Department) and to await their turn to be ‘eligible’ to seek an available place.
Requiring prospective residents to enter a ‘waiting list’ will add a level of complexity for the resident’s family and make entry into the RAC system more difficult. It will also restrict access to those residents who are deemed ‘most needy’ by the department and force others to wait.
It is our view that every person who has been assessed by the ACAT as being eligible for RAC should have the immediate and unfettered ability to source an available residential care place. No one should have to wait until the Department (or someone else) allocates them a licence.
Rather than providing improved access to residential care, this proposal will make the process more difficult and may in fact affect consumers’ access to residential care adversely.
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
Requiring prospective residents to enter a ‘waiting list’ will add a level of complexity for the resident’s family and make entry into the RAC system more difficult. It will also restrict access to those residents who are deemed ‘most needy’ by the department and force others to wait.
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
It is our view that every person who has been assessed by the ACAT as being eligible for RAC should have the immediate and unfettered ability to source an available residential care place. No one should have to wait until the Department (or someone else) allocates them a licence.
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
None. It should not be implemented.
It is our view that every person who has been assessed by the ACAT as being eligible for RAC should have the immediate and unfettered ability to source an available residential care place.
It is our view that every person who has been assessed by the ACAT as being eligible for RAC should have the immediate and unfettered ability to source an available residential care place.
23. What are your views on the validity period of the assigned place for residential aged care?
Model 2 validity period of place
Such a system would be unfair and unhelpful. Consumers will feel pressured at a time when the system should be making their lives easier, not more difficult.
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
Withdrawing a place from a person is akin to telling them that they are no longer eligible to be admitted to residential care.
Under the current arrangements, it would be equivalent to informing them that their ACAT assessment has been withdrawn.
This proposal would have extremely detrimental effects on consumers.
Under the current arrangements, it would be equivalent to informing them that their ACAT assessment has been withdrawn.
This proposal would have extremely detrimental effects on consumers.
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
The current system works well for consumers. When they are ready (ie. in their own time) they decide to search for a residential place. They research the available homes and make a choice. They apply for a place and they receive a response from the home. If a place is available and they are ready, they take up the offer.
This proposal adds another layer of complexity to an already complex and difficult process.
The best way of supporting consumers is to not introduce this system in the first place.
This proposal adds another layer of complexity to an already complex and difficult process.
The best way of supporting consumers is to not introduce this system in the first place.
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
The current system works well and the relative 'power' of consumers and providers is balanced. The best way to overcome any perceived or actual imbalance would be to make more places available.
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?
Approved providers - changes to business, service or workforce model
N/A
28. As an existing approved provider: How would you ensure your aged care home/s remain competitive and attractive to consumers?
Approved providers - how to ensure aged care home remains competitive and attractive
N/A
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?
Non approved provider - becoming an approved provider
N/A
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?
Model 2 how to support sustainable provider operation
N/A
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?
Model 2 role of ACAR in capital finance
Having assisted an approved provider in relation to financing, our experience has been that banks require the provider to have allocated bed licences as a pre-condition of approval of financing.
32. What might be required to ensure the residential aged care sector remains an attractive investment for financiers and lenders?
Model 2 how to ensure sector remains attractive investment
Don't implement this proposal.
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?
Please refer to the answer to question 14.
for consumers from vulnerable cohorts (such as Special Needs Groups, consumers with dementia)?
Please refer to the answer to question 14.
34. Is it possible to attach conditions to being an approved provider, and could these conditions be specific to locations or particular consumer groups?
Model 2 attach conditions to approved provider status
Whilst this would be possible, it could restrict the provider's commercial viability.
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
Rather than providing improved access to residential care, this proposal will make the process more difficult and may in fact affect consumers’ access to residential care adversely.
Ultimately, this model will likely reduce consumer choice.
Ultimately, this model will likely reduce consumer choice.
36. What do you think might be the impact on the residential aged care sector overall?
Model 2 overall sector impact
This would cause a great deal of instability.
Providers will take the opportunity to further saturate already over-bedded affluent areas at the expense of less-affluent areas.
It will make consumers less inclined to turn to residential aged care, even though they may need it.
It will place undue pressure on consumers to take up a bed when a licence is allocated to them even though psychologically they may not be ready to take up such a place.
It will reduce access to people who have been assessed as eligible for residential care until a place is allocated to them.
Providers will take the opportunity to further saturate already over-bedded affluent areas at the expense of less-affluent areas.
It will make consumers less inclined to turn to residential aged care, even though they may need it.
It will place undue pressure on consumers to take up a bed when a licence is allocated to them even though psychologically they may not be ready to take up such a place.
It will reduce access to people who have been assessed as eligible for residential care until a place is allocated to them.
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
Consumers will be less inclined to use residential aged care as the process is simply too hard. It will increase demand for home care services and put much more pressure on families and carers.
38. How could residential respite care places be distributed, and to whom, if residential aged care places no longer exist?
Model 2 respite care
Good question!
This model will increase difficulties and uncertainty for almost all stakeholders.
This model will increase difficulties and uncertainty for almost all stakeholders.
39. What are your views on how to manage extra service status under this model?
Model 2 extra service status
It will become more difficult for providers to offer extra or additional services to residents. The effect of this will be that availability of extra or additional services will likely be reduced, thereby reducing consumer choice.
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
No comment
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
I don't see any benefits to this model.
I see many risks and disruptions and more pain for consumers.
I see many risks and disruptions and more pain for consumers.
What steps/sequencing and timeframes would be appropriate to facilitate a smooth transition?
None. This system should simply not be introduced.
What specific supports or enablers would be required to ensure the changes are understood by all stakeholders and successfully implemented?
Entry into the aged care system is already difficult. Residents and their families are typically over-stretched and emotional at this time. Adding another layer of complexity and another barrier would be heartless.
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
Consumer choice needs to occur and be encouraged once the resident has entered residential care. Encouraging providers to provide additional services that enhance the lives and conditions of residents should be the focus.
The best way of improving access to relevant services for each resident is to improve the availability of places, not the party to whom those places are allocated.
The best way of improving access to relevant services for each resident is to improve the availability of places, not the party to whom those places are allocated.
43. Do you have any other overall comments you wish to provide?
General comments
The model outlined in the attached document would go a long way to addressing the issues that are limiting the growth and expansion of the sector.