Response 491835993

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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)
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Before you start, please tell us about yourself

4. What is your organisation’s name?

Organisation (Required)
The Forrest Centre

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
Ticked Health professional
Workforce association or union
Primary Health Network
State and territory government
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)
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
Ticked 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
The allocation of bed licences through the ACAR provides consumers confidence that providers are independently assessed with respect to the providers capacity to provide aged care services and the liklihood that they will continue to do so throughout the resident's admission to the facility.
Strengths of current arrangements for providers
Providers and their owners, whether they be for profit or otherwise, require some level of certainty as to the long term viability of their significant financial investment in aged care facilities. Building are expected to operate for many years and the allocation of bed licences is critical to the long term investment decisions of providers. The removal of the ACAR bed licence system which provides some long term certainty and replacing it with a market driven system which is susceptible to short term fluctuations will inhibit investment in facilities. The risk that a facility could permanently lose critical occupancy as a result of external market forces, or even internal forces such as a poorly managed critical incident, could significantly reduce investment in aged care services. At a time when many facilities are operating in deficit due to constrained and uncertain funding, wage and operating cost growth removing the ACAR process could result in a reduction in investment and cause providers to exit the industry and cause investors to find more secure opportunities elsewhere.

Design principles for alternative allocation models

9. Are the proposed design principles appropriate?

Please select one item
Ticked Yes
No

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

Please select one item
Ticked Yes
No

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
I believe the current ACAR model is capable of fulfilling the design principles however it is presently inefficient. Providers who have been allocated places must be forced into using those places or commencing meaningful development in relation to those places. Providers can not be allowed to apply for places then not use them in a timely manner as this needlessly restricts alternative investment and, I suspect, inflates forward estimates of government funding on residential care.

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

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

Model 2 views
Providers will find it increasingly difficult and costly to operate under a model which increases operating risk. In a free market providers would simply increase their fees to ensure their risk:return is balanced but in a regulated market where revenue growth opportunities are restricted it means providers will pull back on investment or exit the market all together.

Under the current ACAR model consumers already have choice of provider and routinely shop around for their facility of choice. This may not be the case so much for those living in remote areas but the majority of elderly Australians already do choose their aged care facility and already have the opportunity to access a range of different provider facilities.

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

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
Less tinkering in the system and long term certainty of capital investment return.

General views

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

General comments
Operating Profits of providers are essential if we are to maintain or attract investment in the residential aged care sector. Many providers can not achieve this fundamental element which is the lifeblood of for-profit and not-for-profit providers alike. Deliberately restricted ACFI, negative funding indexation in real terms over consecutive years, expanding compliance obligations in quality and safety, and the need (and desire of providers) (and expectation of consumers) for providers to maintain or increase staffing levels is an unsustainable model which is now critical. In this respect the decision whether to maintain, modify or replace the ACAR model is not as important as the real and pressing priority of ensuring operational funding to ensure providers don't close their doors. I acknowledge many providers are operating profitably but question whether this is market driven efficiency, as is offered as one of the benefits of the ACAR 2 model, or merely reflective of the levels of care and staffing provided which, all too often, fail to meet the expectations of the Consumer and of The Aged Care Quality and Safety Commission .