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)
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Do not publish response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)
Bupa Villages and Aged Care Australia
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
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 one item
not-for-profit
Ticked
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
Ticked
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
mostly offering single rooms with ensuites
mostly offering single rooms with shared bathrooms
Ticked
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
Ticked
Australian Capital Territory
Ticked
Victoria
Ticked
Queensland
Ticked
South Australia
Western Australia
Northern Territory
Ticked
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
Ticked
In a metropolitan area or major city
Current arrangements
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
There are opportunities to improve the current provision of places to better incentivise competition, increase consumer choice and improve the agility for providers to better respond to changing consumer needs and expectations.
A more agile and flexible market will better incentivise competition and therefore better choice for consumers, such as increased innovation to appeal to consumers and allowing new developments in areas that currently only have older products.
A more agile and flexible market will better incentivise competition and therefore better choice for consumers, such as increased innovation to appeal to consumers and allowing new developments in areas that currently only have older products.
Other issues with current arrangements for providers
The current ACAR process constricts providers to plan and respond to changing community expectations and needs in a timely manner. For example, the current process can take two to three years for a provider to obtain land and become “shovel ready” to eventually find they are unsuccessful in their application for places. There is also permanent uncertainty of when ACAR will take place, little transparency of why some providers obtain bed licenses and others miss out, and inflexibility around location requirements.
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
Bupa believes Model 1 could pose a viable interim option to address some of the issues with the current ACAR process and as the sector makes a staged transition to a more consumer demand driven market.
As part of this staged transition, Model 1 should capture and allow for more certainty, flexibility and agility for providers to respond to consumer preferences. Consistent with greater consumer choice, in the longer term, improvements to the current ACAR process as part of the Proposed Model 1 should be considered as part of a staged transition plan which must be agreed by the sector.
As part of this staged transition, Model 1 should capture and allow for more certainty, flexibility and agility for providers to respond to consumer preferences. Consistent with greater consumer choice, in the longer term, improvements to the current ACAR process as part of the Proposed Model 1 should be considered as part of a staged transition plan which must be agreed by the sector.
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
The Productivity Commission stated it would be “disruptive to remove the supply restrictions in residential settings immediately” and “it would be preferable to liberalise supply gradually, allowing time for providers to assess emerging market opportunities and to build their capacity to provide additional services”. The proposed Model 1, as an interim option in transitioning to Model 2, could assist in the ongoing identification of risks as the sector agrees on a staged transition towards fully de-regulating bed licenses, including understanding how consumers will be impacted and how they will respond.
Model 2: Assign residential aged care places to consumers - Overall model
19. Overall, what are your views on this proposed model?
Model 2 views
Bupa believes de-regulation of bed licenses can help promote greater competition and consumer choice in aged care. A robust and agreed staged transition plan is needed to appropriately mitigate risks to best set Australia up for success. As part of this staged transition, any change to the existing model would need to consider a range of factors and risks which we outline below.
Model 2: Assign residential aged care places to consumers - Exploring the potential impacts
36. What do you think might be the impact on the residential aged care sector overall?
Model 2 overall sector impact
As part of a staged transition, any change to the existing model would need to:
1. Ensure it did not inadvertently impact the necessary investment into aged care to meet the rise in demand for aged care services or impact any residents in existing homes. This includes consideration of residents in homes where the provider may have a net liability (approximately 140 providers will have a net liability under this proposed Model when the valuation of bed licenses becomes $nil).
2. Include significant preparatory work by the Government to pave the way for this transition so the sector is adequately supported to continue to provide quality care for residents amid the many changes in aged care.
We note this consultation in the context of the 2018-19 Budget measure which gave in principle support for alternative arrangements to provide greater choice for consumers, as recommended by David Tune AO PSM’s Legislated Review of Aged Care. While the Tune Review supported the transition to a model that allocates a residential place to the consumer rather than the provider, it also highlighted there is “significant work to do before government could safely remove supply controls while ensuring the system is fiscally sustainable for government and equitable for consumers”. This includes “equitable and sufficient contribution by care recipients to their costs of care” and “a robust system for assessing eligibility for subsidised services”. The Government has not progressed this work to date, which was highlighted in Mr Tune AO PSM’s submission to the Royal Commission in May 2019.
1. Ensure it did not inadvertently impact the necessary investment into aged care to meet the rise in demand for aged care services or impact any residents in existing homes. This includes consideration of residents in homes where the provider may have a net liability (approximately 140 providers will have a net liability under this proposed Model when the valuation of bed licenses becomes $nil).
2. Include significant preparatory work by the Government to pave the way for this transition so the sector is adequately supported to continue to provide quality care for residents amid the many changes in aged care.
We note this consultation in the context of the 2018-19 Budget measure which gave in principle support for alternative arrangements to provide greater choice for consumers, as recommended by David Tune AO PSM’s Legislated Review of Aged Care. While the Tune Review supported the transition to a model that allocates a residential place to the consumer rather than the provider, it also highlighted there is “significant work to do before government could safely remove supply controls while ensuring the system is fiscally sustainable for government and equitable for consumers”. This includes “equitable and sufficient contribution by care recipients to their costs of care” and “a robust system for assessing eligibility for subsidised services”. The Government has not progressed this work to date, which was highlighted in Mr Tune AO PSM’s submission to the Royal Commission in May 2019.
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
This proposed change must considered within the broader context of other aged care reforms currently being considered by the Department, as well as its interdependencies with workforce, quality and funding to ensure a sustainable sector that Australia deserves, now and into the future.
This includes consideration of how a more consumer demand driven market will function alongside – and further enhance – future policy reform agendas, such as the greater integration and streamlining of the home care and residential aged care systems; the proposed new funding model; future regulation of Additional Services; enhancing quality and safety in aged care; and improved transparency for customers.
This includes consideration of how a more consumer demand driven market will function alongside – and further enhance – future policy reform agendas, such as the greater integration and streamlining of the home care and residential aged care systems; the proposed new funding model; future regulation of Additional Services; enhancing quality and safety in aged care; and improved transparency for customers.
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
A significant transition time is needed for the sector to adequately prepare, such as workforce planning. For example, significant work will need to be undertaken to support the aged care workforce and ensure any changes and occupancy fluctuations in a more consumer demand driven market don’t leave the aged care workforce worse off. Workforce planning will also need to consider the pool of aged care workers in certain locations where demand already exceeds supply.
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
As a nation, we need to be open to new approaches to ensure the expectations and changing needs of senior Australians are met. Moving to a more consumer demand driven market is one way to drive quality, choice and innovation of care, lifestyle and service delivery in aged care.
Bupa supports increasing consumer choice in aged care. The 2011 Productivity Commission into Aged Care and David Tune AO PSM have offered recommendations on how the sector can make a staged transition to a more consumer demand driven market. As part of this staged transition, careful consideration must be given to understanding the risks related to the deregulation of bed licenses and developing appropriate mitigation strategies to best set Australia up for success.
This consultation also forms an integral part of the wider discussion on the future direction of aged care in Australia, including its interdependencies with workforce, quality and funding to ensure a sustainable sector that Australia deserves, now and into the future. Any risks and mitigation strategies must be considered in this wider context.
Bupa supports increasing consumer choice in aged care. The 2011 Productivity Commission into Aged Care and David Tune AO PSM have offered recommendations on how the sector can make a staged transition to a more consumer demand driven market. As part of this staged transition, careful consideration must be given to understanding the risks related to the deregulation of bed licenses and developing appropriate mitigation strategies to best set Australia up for success.
This consultation also forms an integral part of the wider discussion on the future direction of aged care in Australia, including its interdependencies with workforce, quality and funding to ensure a sustainable sector that Australia deserves, now and into the future. Any risks and mitigation strategies must be considered in this wider context.
43. Do you have any other overall comments you wish to provide?
General comments
Bupa welcomes ongoing consultation on opportunities to increase consumer choice in aged care, including the Proposed Alternative Models for Allocating Residential Aged Care Places.
Bupa looks forward to participating in further consultation with consumers, providers, Government and other stakeholders to progress the sector towards a more consumer demand driven market.
Bupa looks forward to participating in further consultation with consumers, providers, Government and other stakeholders to progress the sector towards a more consumer demand driven market.