Response 399878072

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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)
Ticked Publish response, but keep my name private (include my organisation's name)
Publish response anonymously (remove both my name and organisation's name)
Do not publish response

Before you start, please tell us about yourself

4. What is your organisation’s name?

Organisation (Required)
City of Kalamunda Aged Care Advisory Committee

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
Ticked Local council
Commonwealth agency
Lender or investor/financier
Other

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
Ticked 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
The City of Kalamunda is submitting through it Aged Care Advisory Committee in order to highlight the potential reduction in suitable aged care facility accommodation in ‘thin markets’ or areas where infrastructure costs may be higher. The City of Kalamunda is situated within the Perth Metropolitan area in the eastern hills with an escarpment which creates building challenges. Under the current arrangement the City is well under its allocation of bed licenses due to poor operationalisation of allocated licenses. This results in many local residents being unable to access aged care within their local area.

The current model has the potential to ensure bed allocations are distributed equally across regions and ensure aged care provision occurs in all localities and not only in those where costs (build environment and labour) are lowest.

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
A current flaw in the allocation model can lead to organisations being allocated bed licenses with no incentive to operationalise. The enforcement of currently regulations around building timeframes would improve this situation.
For example, in the City of Kalamunda is currently well below the Aged Care Provision Ratio of 125 aged care places per 1,000 people aged 70 years or over by 2021–22. The City of Kalamunda region is also below the 30 June 2015 statistics of 111.5 operational aged care places per 1,000 people aged 70 or over.
An additional pressure on access to residential aged care facilities is early or avoidable admission due to lengthy wait times for suitable home care.
Other issues with current arrangements for providers
Residential Aged Care Facilities (RACF) – identified problems
The experience of residents in RACF is undeniably improved when family and friends are able to maintain relationships through regular visiting.
In an outer metropolitan area such as the Hills Region of Perth, the majority of families therefore are seeking an RACF in the local area.
The current situation where providers are holding bed allocations and not operationalising them leads to a severe shortage of options for local residents.
It is critical that any Model provide an adequate number of concessional places in all regions.
The City of Kalamunda is a region with a critical lack of RACF places (shortage of approximately 300-400 at 2019) and all issues are exacerbated.
The City of Kalamunda has too many examples of families being separated by having to go to other far away regions to find places.

Design principles for alternative allocation models

9. Are the proposed design principles appropriate?

Please select one item
Yes
Ticked No
Please elaborate on your response
If the demand Model is adopted, it must be able to provide the principle of equity in regions like Kalamunda where there is currently thin supply.
The principle of equity and distribution is critical to ensure providers do not focus developments in areas where economies of scale can be maximised. Provision needs to be made to ensure regulation of any demand model ensures that RACF developments are spread equally, particularly in thin areas such as Kalamunda.
Any adopted Model must ensure families are not separated by distance.

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

Please select one item
Ticked Yes
No
Please elaborate on your response
Any adopted Model must ensure families are not separated by distance.

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 City of Kalamunda is most likely to be best served under the existing model, rather than the alternative proposed Model 1.

Government action must ensure adequate residential beds are provided in areas of need, addressing increased building costs, infrastructure needs, zoning and environmental issues which currently act as disincentives to RACF providers. Cooperation between all levels of government is essential, with Federal and State taking a lead in identifying need, allocating licences to such areas and liaising with local governments and aged care providers to encourage and facilitate development.

The City of Kalamunda supports the suggestion in Model 1 to reduce the number of non-operational residential aged care places to maximise the availability of places to consumers; and improvement to the administration of ACAR and places management processes.
The City believes it is essential improvements are made to support the consumer to find and select the most appropriate vacant residential aged care place.
The City has significant concern that full adoption of Model 1 would lead providers to develop future facilities in geographic areas that meet their needs rather an the needs of the consumer.

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?
Equitable access will require the Federal government to monitor and respond to areas that fail to meet the predetermined government ratios for safe provision of residential aged care.
for consumers from vulnerable cohorts (such as Special Needs Groups, consumers with dementia)?
The government must also ensure adequate allocation for dementia specific beds and facilities in all RACFs with the rising demand for these in the future, given that 25 – 30% of people over 85 years are likely to experience this condition.
Adequate allocation of respite beds is also necessary.

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

Model 1 variants
Variations would include the government regulating to ensure thin markets are addressed as well adequate provision for dementia and respite places to meet the Aged Care Provision Ratio of 125 aged care places per 1,000 people aged 70 years or over by 2021–22.

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
Any market based, consumer driven Model must ensure adequate RACF beds are available in all areas to allow supply and demand to operate to the benefit of the consumer. Easy access for consumers to information on available beds and a simple method of registering a request for a place with multiple providers would be essential.

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 major impact on the City of Kalamunda stakeholder group will be the disincentive for providers to build in the local area if locational controls on the distribution of residential aged care places are removed. This is due to increased infrastructure costs in areas constrained by environmental, water, sewerage and geological constraints.

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

Model 1 potential overall sector impact
Potentially a concentration of aged care facilities in areas/suburbs where the cost of provision, including building cost, is lower.

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
Currently the home care package program is experiencing significant delays and failing to meet the needs of consumers. This already leads to avoidable admissions into RACFs. If residential aged care is further limited in the local area this problem will only be exacerbated.
The current lack of genuine respite care, which is critical in order to extend a person’s ability to be supported at home and prevent premature entry, also provides stress on RACFs.

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
As the City of Kalamunda does not support Model 1 as presented it is not able to provide a response.

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

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

Model 2 views
The benefit of Model 2 will be to provide consumer control of funding for RACF places and the ability to negotiate for services. However, it will only work if excess appropriate places are available in the desired geographic area.
The City of Kalamunda covers a geographic area that is within the greater metropolitan area however, has significantly increased costs associated with building a RACFs due to bed rock and resultant infrastructure issues.
This Model 2 removes any incentive for a provider to build a facility in an area with these additional costs and would likely lead to fewer facilities in the area and increased burden of travel on family and friends to access RACFs built on the escarpment.
The key potential problem with Model 2 is that queuing will persist for allocation as is occurring in Home Care Packages.

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
The City of Kalamunda has significant concerns that a national queue could result in consumer needs not being met as demonstrated by home care packages.

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 current experience in home care package queues does not give confidence that date of approval and urgency of need are ensuring best outcomes for consumers.

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
Potential factors:
- Physical and mental health of the person being assessed
- Physical conditions in the home - eg stairs, lack of rails and supports in bathroom and toilet, narrow doorways.
- Physical and mental ability of partner/family/carer to provide adequate care.
- Availability and quality of support services coming into the home
- Home situation becoming unmanageable whilst in the queue.

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

Model 2 validity period of place
When the consumer is being asked to take the lead role it is imperative that provision is made for people of non-English speaking backgrounds, people with disability and people limited by stress. We have experienced failure in the home care allocation due to lack of understanding on the part of the consumer regarding validity periods and allocations.

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
Give consideration to professionals assessors (doctors, social workers and other ancillary health care workers) on a case by case basis.

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 complex process and responsibility on the consumer to identify, assess and choose an appropriate RACF and negotiate a suitable arrangement with the providers would require support of an expert advocate (financial advice and navigating the system) to help ensure a good outcome. Such expert individuals/organisations should be a funded part of the process.

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
Adequate numbers of beds overall and, it would seem that a proportion of government funded or concessional places would still need to be provided. Adequate advocates to navigate system.
True equity also includes access to local places where a provided has no incentive to build in a thin market this cannot be achieved.

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
Not applicable

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
Not applicable

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
Not applicable

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
Not applicable

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
Whilst the City of Kalamunda is not a provider of aged care it supports capital financing particular in areas of thin markets.

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
Incentives such as easier access to land, subsidised land and infrastructure where needed, streamlined planning and approval processes at all levels of government. Willingness by local governments to prioritise the needs of the elderly for residential care in areas of shortage above other community considerations till that need is met to accept Federal Government standards.

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?
Incentives such as easier access to land, subsidised land and infrastructure where needed, streamlined planning and approval processes at all levels of government. Willingness by local governments to prioritise the needs of the elderly for residential care in areas of shortage above other community considerations till that need is met to accepted Federal Government standards.

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
In areas of need or thin markets, outer metropolitan/semi-rural/regional some environmental requirements may be imposed, as are aesthetic conditions at present. Requirements for a proportion of respite places in a facility could be a condition of licensing to meet established need.

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 in Model 1 the lifting of geographical allocation has a potential negative impact on ensuring consumers have access to local RACF.

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

Model 2 overall sector impact
Not applicable.

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
No comment.

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

Model 2 respite care
The Commonwealth Government to make funding arrangements to provide respite in State government facilities (hospitals etc) or establish Commonwealth respite facilities in all areas to support the Commonwealth Home Care Program.
Such government respite beds could be made available under contract to organisations providing Home Care Packages as a service to their clients and could be marketed by them as an extra benefit to their offering. This would help ensure the beds were fully utilised, as the persons in most need would be part of the process via the Home care provider.
Investment is required in purpose build respite facilities particularly catering to the needs of people with dementia.

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

Model 2 extra service status
Not applicable.

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
No Comment.

General views

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

General comments
Response
The City of Kalamunda is experiencing a serious shortage in the provision of aged care places with the current total operational ratio per 1000 people aged 70 and over at less that 90 which is significantly below the 30 June 2015 statistics of 111.5 operational aged care places per 1,000 people aged 70 or over. There are currently 243 beds available at RACF within the City of Kalamunda.

To date two facilities have been commissioned:

1. Redacted text160 beds to become available in 2020
2. Redacted textRedacted text additional 50 beds available by 2021.

In addition to the RACF beds noted above there is also a requirement, under Commonwealth Government targets, for 2 respite beds per 1000 people >70 years, so these figures need to be added to the places required. eg increasing the 2026 figure to 723 beds.

Currently Kalamunda has only 1 identified respite bed.

The City of Kalamunda is facing a crisis and is of the view that the move to consumer demand driven bed allocation model being proposed will only exacerbate the shortage of supply to outer metropolitan regions.