Response 921728131

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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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Before you start, please tell us about yourself

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
Ticked 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

6. Where does your organisation operate (if applicable)? Otherwise, where do you live?

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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
none
Strengths of current arrangements for providers
they get bulk funding, and has flexibility of how they wish to use these funding

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
very closely addressed in discussion paper, but not welcome by the service user at all.

it is always a matter of:
the government spent millions to choose the providers, support best providers possible, using example of chosen best chocolate cake in the world
but the customer wants a bowl of noodle instead.

the millions are wasted each year, but no one is happy.

quality is in the eyes of beholders, so often the clients have their own reasons why they are going ahead with a provider.

with HCP as example, in the past, there were not more than 2 chinese org funded in sydney, but since 2017 we are able to take on the clients directly, we have been told that that chinese funded org was charging 30% of funding, and was asking $65 per hour.

so the family had a choice, and obviously, they will not be forced going ahead with that chinese org.
Other issues with current arrangements for providers
the provider is in control so they are telling the services user a lot of unreasonable demands.
Are these problems occurring at national level, or only in certain areas (e.g. rural, regional and remote areas) or for particular consumer groups?
yes, national wide.

with CDC, the rural clients will not necessarily go ahead with rural providers neither, as each client chooses value for money services.
What evidence supports your view that these are significant issues which need to be addressed?
it is demand and supply.

when the supply is limited, then the services user is restricted of get their preferred providers, then costs arises as the providers can dominate the market.

those none for profit made millions through their poor advices to the government, at the disadvantage of the service users, it is time to let it go.

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
we should stop fixing model 1, it is basically should be abolished.

we should improve model 2 to make it simple.

what a relief with no ACAR for HCP. it is huge relief for the gov, and huge relief for HCP providers, as generally each year, we need to spent 3 months of the year to prepare ACAR application. not to mention all the money wasted for "networking", attending "conference", "marketing", and many more, an attempt to be heard, and to be seen, and to establish "good relationships" etc.

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

Please select one item
Ticked Yes
No
Please elaborate on your response
we have written a detailed reply, hopefully it can be attached at the end.

we strongly argue to use model 2 as quickly as possible, but further simplify model two.

we also suggested of merging accreditation body:
merg residential accreditation body with aged care commission.
abolishing aged care commission quality assessment tasks as they are doing a horrible job.

we also suggested of using ACAT to assess residential care level 1-4 at the time of assessing the clients at their home for residential care, and HCP. and plus respite care.

So this allows one visit to cover both, and service user can choose if they wish to use residential care or HCP.

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
We are not interested at all, it is basically fundamentally wrong approach.

we strongly argue to have model 1 abolished as soon as possible.

the model one problem:
it creates nepotism, corruption, imaging with model 1, how often those people from the department, going for talks at conferences and seminar?
it forces the gov doing ACAR each year, perhaps $500million wasted national wide for assessment and reading all the applications.
what this done to the providers was to waste a huge amount of money, to do the application, waste on works "to be seen, to be heard" this was why the providers are forced to attend those conferences and seminars!
to the services users, they have no say in allocation of the places.
last, it was lucky dip and parachute where the gov allocate the places to providers other than their states. good locate providers are pushed aside.

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?
as long as the funding is going ahead with the client, the client chooses.

we have rural clients who are now choosing sydney providers, as they found their local rural providers are too expensive.

the pricing from us between rural and sydney metro is the same, so rural providers found the benefits of using sydney providers yet getting their rural workers.

so to the gov, as long as funding linking to the services user, and encourage small providers to participate in residential aged care, many small providers can be cheap, accessible, and flexible,
for consumers from vulnerable cohorts (such as Special Needs Groups, consumers with dementia)?
there are 2 approaches if we are the small provider for residential aged care:
not to mix dementia with all the dementia clients
or mix dementia clients altogether, but staff are taking turns.

details explained in our letter.

with model one existing providers, they should use option 2.

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

Model 1 variants
model one is fundamentally so wrong, so it should be abolish, no further attempt should be tried, it will be continuously wasting of money.

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
once model one is abolished, the industry is not going to falling apart:
each existing resident will be signed to a package level
they will be informed of how to choose a provider,
but many will stay at existing premises as they do not have the freedom of change
so change will only be a few clients.
this means the operator might lose one or two clients, but overall, they will keep their residents.

the new small providers will be the one taking on the clients one by one, genuine decent small provider is not going to have their room all filled immediately anyway, they too take on one by one.

so it will be a slow transition for both existing provider and new small providers.

therefore, the industry will not be falling apart at all.

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
model 1 has no hope,

as a HCP provider, we applied residential care for last 10 yrs with no success, we really do not believe if there is any hope of fixing the model 1.

it is only pocket profit to those "aged care consultants", and gov keeps losing millions to support ACAR around

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
improvement management? another ways of those supporters asking the gov to waste millions.
What steps/sequencing and timeframes would be appropriate to facilitate a smooth transition?
pls give 3 yrs, but no more:
because we need to approve small providers to get into the market. pls do choose small providers from HCP providers for financial and skills and experience reasons.
small providers still need to comply with regulations such as installing water pipes to each room, and make some modifications etc, as these requiring council approval. it takes more than 12 months.
set regulation to help small providers going through the council and going through land environment court, details explained in attached letter.
What specific supports or enablers would be required to ensure the changes are understood by all stakeholders and successfully implemented?
periodically set national wide talks for both providers and service users.

try not to make the mistake like NDIS to separate the talks between service users and the providers, it is waste of money.

just have a talk for both, and periodically means, going through a talk at an area, for example in sydney
go to western sydney, this time at blacktown, next time at penrith, but final time at windsor as such, not to have the same place every time.

so 3 times to cover western sydney. but no need more than that , any more will be wasting of money.

by having a talk with both, the service user can see the point of view from the providers, it can help them to choose the providers.

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

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

Model 2 views
yes, a totally different approach, a service user centred approach.

in a commercial world, it is always the customer who have the money, go to the shop, to buy the things they want.

other way around just will not work.

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
using the similar queue from HCP.

if no places, then offer level 4 of HCP, it will work as with our services, our level 4 clients getting 16hrs a week. so often helps the client resolving their key issues at home.

on the other hand, a good HCP providers stop their clients going to nursing home, as often providers like us, the family find a huge relief for caring their old ones at home, and they want to keep client at home, so they:
no need of traveling to nursing home visiting their loved ones
they can keep their loved ones pension.
it costs them nothing for caring loved ones at home, as our company charges them nothing.

so in the future, with good HCP providers like us, they will be less people going to nursing home.

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
some reasons that the clients do need to be put on top of the lists:
the home is not suitable for home based care, physically
no human resources for caring old ones at home, like single person, or family and friends.
sign of abuse from the family members, for example, daughter family living with mother but not taking care of the mother. the son living with the mother but won't take care of his mother as all he wanted was to take over the house.

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

Model 2 validity period of place
as people's condition can change, so if they have not offered a place, then ACAR should visit them at least once a year, assuming there is provider from HCP taking care of them at home.
the client will have all the hours they want on level 4
they will have a vital call and emergency arrangement done by their HCP provider.
their HCP provider can going into the portal asking for urgent review if the situation changes. so this is another way of fast track the approval.
on the portal, HCP providers generally can download the support plan of their client, and on it is their initial ACAT assessment personnel and contact phone number. so if the situation changes, their HCP provider can call ACAT immediately.

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
when ACAT does the assessment for HCP and residential care, they can do both assessment, the approval can be both, so it will not waste time to go there again to assess for residential care.

once the client is offered both + respite care, the client or their family can choose.

often the client did their shop-around might decide to go ahead with HCP, for reasons explained above.

then once there is a funding available for example, they get a reference code for HCP, and another reference code for residential care.

if the client chooses HCP, then their reference code for residential care will be terminated. by such action, the gov can see the places is returned to its funding pool.

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
not a lot,

just make sure to do the talks around national wide, and put residential care providers list on my aged care residential care website. for clients' navigation.

the details of residential care provider, needs a bit more details as what areas they have the facility. for example, a sydney provider will not have a facility at albury.

the area must not be western sydney - a board name, but specific subbern name, like blacktown, or mt druitt etc.

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
for special needs group, the gov try to allocate higher level of funding, this way, provider like us will be very happy to take on.

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
we are not an existing residential care provider, so can not comment.

but we believe the impact at the beginning is very small, they will be still able to keep their existing workforce, and number of staff. as explained in our letter.

but getting new clients, they will have to compete.

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
all commercial business will know how, just image those hotels they stayed.

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
yes, we will.

it is harder to go through the council.

therefore, we are asking for regulation support, we have addressed them in our letter. 9 pages.

basically the department of land must introduce new causes to support such new way of residential care, at moment, they only have nursing home, or boarding house rulings.

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
might be in area of how they use their bond, and how bond is kept, no one wants to pay these days.

so going to a residential care, currently there are 2 sources of income:
bond
and funding

currently the bond is kept with the provider, how about bond to be kept by the department, just like residential tenancy bond, the bond is kept with fair trading. the interest is going back to the bond.

if the client or the provider wish to access the bond, the they can make the application.

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
ACAR should be abolished, no role for ACAR system to be kept just for assess capital funding.

capital funding can be applied anytime of the year, small provider once approved for residential care, they can immediately apply for capital funding with pre-set criterias.

details pls see our letter.

we strongly suggest the funding to be used and only catered to small providers, details explained in our letter.

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
it should not be attractive for financiers and lenders at all.

they are in the job for profits, and once they get big, they just manipulate the government for more money in to the sectors, they have dome enough damage already.

it is meant to be the providers, small providers are flexible and more competitive, and can introduce better care, and innovative way to keep up clients' satisfaction.

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?
the market will change the situation, for example, if sydney provider have a client who is at albury, they might decide to arrange a place at albury just to accommodating this client.
for consumers from vulnerable cohorts (such as Special Needs Groups, consumers with dementia)?
just provide higher level of funding, all problem can be solved. as the providers will fight to these clients, thus, promised of how to meeting their needs.

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
the condition that we suggest is to only approve residential care providers who are HCP providers first, for skills, existing workforce, and experience in aged care.

for too long, we have consumer groups, we have council, we have none for profit community group, running a highly skills required area, the aged care became like a family affair.

the reality is the expectation is getting higher and higher, we need professional in health to run aged care, not social workers, welfare offices, good hearted people,

we need nurses, and doctors to run aged care.

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
nothing, we have our own company property, and we just need a bit of support on capital funding, so we can refurbish our property quickly.

we also need support at state level for going through our refurbish +small changes on property application to go through.
at low residential zone, special approval for small providers who gained residential care approval, to use the land for commercial purpose, who are applying for residential care at low residential zoning area.
for medium and high density zoning area, approval for commercial usages
not to stuck small providers in the land and environment court.

with these special cause in the state level, thus, the council can pass small providers' applications quickly.

also if the matter does go to land and environment court, the small provider get special consideration,

at moment, no one know from council to judges at land and environment court, so they can support in favour of small providers, and thus, they are the ones dragging the matter, and created additional burden to the small providers.

this is why saying the small provider can not afford refurbishment is not actually correct.

to refurbish and to make small changes, a small provider have to go through council, before that they need to use their saving to hire town planner and architecture. so these process are not cheap.

if the council try to be difficult, then go through land and environment court, and often the costs will be even higher for legal proceeding.

so capital grant for refurbishment is last big of work. the easiest part.

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

Model 2 overall sector impact
we hope to see many boutique small providers in major city's metro areas.

many aged will not need to travel to the country to find a good accommodation. another kind of aging in place, not at their home but at their subbern, where they want to stay, and stay in an area where they are familiar with.

we will see resort style of country providers will be consolidating their operation. for long time, they find hard to get the staff, and this problem will exacerbate.

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
accreditation, pls do merge them,pls do abolish aged care commision doing HCP assessment, as they are doing a horrible job.

with ACAT, they get slightly additional work as in the past, they do HCP assessment, now they need to issue 3 approvals: residential care, respite care, and HCP at the same time. so the services user can choose where they want to go.

linkages between HCP and residential care, so the approval of the level's funding will be arriving at the same time, for example:
HCP funding approval for level 3
residential care level 2

different code but arriving at the same time, so the client can choose, if they choose one, then another one automatically lapses, so the funding can be returned to the pool for other clients.

state housing supply, might change too, as less people going to house.

we are happy with model 2, and many are waited for a very long time.

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

Model 2 respite care
it is according to the waiting list like HCP.

as to the number of level 1, or number of level 4, gov can calculate the numbers for each level from its pool of funding amount.

like HCP, end of financial year, might be a time to check the pool, but with HCP, we find them doing well, as once the clients are deceased, the money is returned to the pool, then they immediately activate the funding for people in the queue.

so technically, it is moving a lot faster instead of clients having to wait till next ACAR around.

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

Model 2 extra service status
no extra services, all these status should be cancelled.

to help existing providers who are argument for extra status, they can convince their ACAT assessor if the clients needs a high level of funding, for example, instead of level 2, providing level 3 funding.

if they can achieve that, then their client can have a higher level funding to cover their extra services.

but ultimately, no more extra services, a package is meant to include everything.

extra HCP? we do not have, so pls do keep it simply and manageable. thanks.

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
pls do not keep ACAR just for capital grant allocation!

ACAR should be abolished.

as long as we/small providers have:
regulatory support in state's gov cause on using the land and developing the land by small providers, this helps to resolve a big hurdle.

capital grants does not have to be an annual event, it can be a pool of money but accessible by the small providers with an application.

we have keep saying small providers are the first priority here, and details of why is explained in our letter.

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
1. start working on small HCP providers submit their application to become residential aged care approved providers.
2. start working on state regulatory support.
3. start working on ACAT for approvals from 1/7/20xx.
4. develop model of a service agreement.
5. we feel the bond is a tricky problem, and we suggested bond to be paid to the department. so the system has to be ready.
6. last is finding a way to have the existing resident signing their service agreement with their existing residential aged care providers. we find getting the existing provider will not have such job done well, it is better to get ACAT staff to do them, so at the time of signing, or cooling period as such, ACAT staff can provide required options and alternative to the residents.

What steps/sequencing and timeframes would be appropriate to facilitate a smooth transition?
not more than 3 years,

any longer, the gov will need to go around to do the talk again.
What specific supports or enablers would be required to ensure the changes are understood by all stakeholders and successfully implemented?
mentioned above, go around national wide to talk about the change.

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
the department might not be aware that since NDIS introduced independent supported living/accommodation, the providers had so much the problem from the state and the council.

the judges in the land and environment court had no idea of what we try to do.

as a result, we get disadvantaged, and we wasted a lot of money trying to get the approval.

NDIS does not support providers going through the court and land and environment, not even with a small letter of support, it becomes all its approved provider own fight.

we hope this will not happen to residential aged care providers, as many small providers will be applying to council in the major city's metro areas.

therefore, in many sections, we mentioned regulatory support in state level, and adding additional cause to support such development.

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

General comments
yes, we have written a letter in response to discussion paper. pls see attached.