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Author: Aaron Banick

Our New Suite of Cognitive Impairment Resources

Posted on by Aaron Banick

Cognitive impairment is a broad term referring to difficulties that a person has with memory, thinking, their ability to learn new things, concentrate and communicate with other people. Cognitive impairment can be associated with a range of conditions, including dementia, delirium, an acquired brain injury, intellectual disability, and others.

People with cognitive impairment face greater barriers to receiving safe, high-quality care, and increased risks of preventable harm during care. The recent Royal Commissions into Aged Care Quality and Safety, and Violence, Abuse, Neglect and Exploitation of People with Disability have concluded that people with cognitive impairment are vulnerable to harm when systems are not implemented which meet their needs and protect their human rights.

Dementia and the Care Reform Agenda

This is particularly true for people who live with dementia, who routinely face challenges in receiving safe, accessible care which meets their needs and respects their human rights. The Australian Institute of Health and Welfare estimated that:

  • in 2021-2022, more than half of individuals living in residential aged care facilities had dementia;
  • Australia’s ageing population will contribute to an increased in the number of people living with dementia, which is predicted to more than double by 2058; and
  • in 2022 dementia was the second leading cause of death.

In late 2024, the Australian Government published its first National Dementia Action Plan which outlined a whole-of-government response to improve the quality of life and protect the rights of people with dementia. The Action Plan reiterated the reform agenda which has been ongoing across the health system, in aged care, and disability support services to better support people with cognitive impairment.

Actions and requirements relating to the care and support for people with cognitive impairment have been integrated into a number of practice standards, including the:

National Safety and Quality Health Service (NSQHS) Standards

  • Actions 5.29 and 5.30 under the Comprehensive Care Standard
  • Relevant to other actions including 1.15, 1.30, 4.10, 5.09, 5.33, 5.34, 5.35, and 8.05

NDIS Practice Standards

  • Considerations for people with intellectual disability and others who may have cognitive impairment are at the core of the NDIS Practice Standards and Supplementary modules for specialist behaviour support service providers.

Strengthened Aged care Quality Standards

  • Improving the quality, safety and accessibility of services for individuals with dementia was a key objective of strengthening the Aged Care Quality Standards.
  • Actions under Outcome 5.6: Cognitive Impairment
  • Actions under Outcomes 1.1, 2.2b, 2.9, 3.1, 3.2, 4.1b, 5.3, 5.4, 5.5 and 7.2
  • The Commission has indicated in their recent draft Audit Evidence Collection tools, that they expect organisations to have a current Cognitive Impairment Policy.

Our New Cognitive Impairment Resources

To help providers address this important issue and implement appropriate procedures, we’ve put a lot of work into developing resources which incorporate a range of rights-based considerations for supporting people cognitive impairment.

Our New Cognitive Impairment Policy Template:

Our new policy template addresses key considerations including:

  • Partnering with people with cognitive impairment, and safeguarding their rights to safe and effective care;
  • Supported decision-making and advance care planning;
  • Considerations for effective behaviour support planning and minimisation of the use of restrictive practices;
  • Considerations for managing medications, including reducing the use of psychotropic medications; and
  • Considerations for comprehensive care, including:
    • Nutrition, eating and hydration
    • Pain management
    • Falls prevention
    • Preventing and managing delirium

Updated Policy Templates:

We’ve added new sections to a number policy templates to incorporate additional considerations for supporting people with cognitive impairment, as well as linked them to relevant standards, including these ones:

  • Info: Intimacy and Sexuality (Aged Care)
  • Info: Nutrition, Meals and Hydration
  • Policy: Advance Care Planning
  • Policy: Clinical Deterioration
  • Policy: Diversity and Cultural Inclusion
  • Policy: Elder Financial Abuse
  • Policy: Intake and Referral
  • Policy: Intimacy and Sexuality (Aged Care)
  • Policy: Key Elements of Client Safety and Wellbeing
  • Policy: Managing Violence and Aggression
  • Policy: Medication Management
  • Policy: Nutrition, Meals and Hydration (Aged Care)
  • Policy: Pain Management (Aged Care)
  • Policy: Partnering with Consumers
  • Policy: Safety and Security in Residential Aged Care Facilities
  • Policy: Supported Decision-Making and Dignity of Risk
  • Policy: Use of Restrictive Practices (Aged Care)
  • Policy: Use of Surveillance Devices in Residential Aged Care Facilities

Our self-assessments supporting safe care for people with cognitive impairment

We have a number of self-assessments which support safe and accessible care for people with cognitive impairment including the specific requirements of the Delirium Clinical Care Standard and Psychotropic Medicines in Cognitive Disability or Impairment Clinical Care Standard.

We are continuously reviewing our resources to ensure that they incorporate best practice and especially based on input from our members. We have taken care to ensure that the updated resources are linked to relevant actions in key standards self-assessments as suggested evidence, to support ease of use. 

You can access these resources by logging into your SPP account and searching for them in the Reading Room or with a relevant keyword like “cognitive impairment”, “dementia”, or “delirium”. 

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Spotlight on Safeguarding Children

Posted on by Aaron Banick

Ensuring a safe environment for all children and other vulnerable people is a collective goal across the community, motivated by the urgent need to respond to the concerns and deficiencies raised by concurrent state and federal inquiries regarding the handling of child abuse. The introduction of the National Principles for Child Safe Organisations, state-level Child Safe Standards and related reforms have been significant priorities for care organisations who provide valuable services to the community. 

We’ve remained close to the continuing implementation of consistent Child Safe standards across all states and territories. In step with these developments, we continue to build and and update self-assessments and resources to help organisations understand and track their compliance obligations, and develop consistent practices and procedures to safeguard children and vulnerable people in their care.  Below is an update on recent developments.

Queensland Child Safe Standards

Last year, the Queensland Government introduced the Child Safe Organisations Act 2024 in order to strengthen the safety of children within Queensland. 

The Act introduced Queensland’s implementation of the Child Safe Standards, which include ten standards that are based on the National Principles, together with an overarching requirement to provide an environment which promotes the cultural safety of Aboriginal and Torres Strait Islander children at all stages of implementing the Child Safe Standards (the “Universal Principle”).

The Act also introduced a Reportable Conduct Scheme which requires organisations to implement systems to investigate and report allegations of harm against children. The Scheme largely aligns with similar schemes operating in NSW, Victoria and Tasmania, and requires subject organisations to comply with certain requirements and timeframes related to the reporting and investigation of child safety concerns. 

Regulatory oversight by the Queensland Family & Child Commission (QFCC) for the Child Safe Standards will commence from 1 October 2025 for certain organisations including services for children with a disability, with additional organisations becoming subject to the scheme in early 2026. The Reportable Conduct Scheme will commence for the first cohort of subject organisation on 1 July 2026. More information regarding the timeline for implementation can be found on the QFCC website.

Queensland Child Safe Standards Self-Assessment

In December 2024 we released our self-assessment to help organisations understand and track their compliance with the requirements of the Queensland Child Safe Standards and the Reportable Conduct Scheme. The self-assessment was developed based upon best-practice considerations drawn from the National Principles, and Child Safe Standards implemented in other states. 

The QFCC is currently developing additional guidance material related to the Child Safe Standards. We are following this process closely.

Reportable Conduct Scheme Modules

We’ve recently added modules to our Child Safe self-assessments for NSW, Tasmania and Victoria to help organisations understand the core requirements of each state’s Reportable Conduct Scheme. Each state’s RCS is different, so for providers operating in multiple states these modules will help them understand the similarities and differences.

Supporting Cultural Safety & the Universal Principle

The National Principles and state Child Safe schemes have reiterated the importance of providing a culturally safe environment for all children, and the need to protect the rights of Aboriginal and Torres Strait Islander children. We have taken special effort to incorporate best practice considerations into our self-assessments and resources. 

  • Tasmania and Queensland introduced the concept of the “Universal Principle” which must be considered within each child safe standard. 
  • Victoria has an additional standard which includes considerations for cultural safety. 
  • NSW includes clear considerations for cultural safety in Standard 4: “Equity is upheld and diversity is taken into account”, which is also relevant to the National Principles. 

Updating our Child-Safe Resources

We’ve recently reviewed and updated our Policy: Child Safe, based on insights gained from child-safe schemes and guidance material implemented in each state. 

We’ve added additional detail in these areas:

  • Defining clear and actionable responsibilities for organisational personnel;
  • Additional focus on addressing child safety as a regular part of risk management; 
  • Greatly expanding considerations for reporting, investigating and responding to incidents of harm and abuse; and
  •  Additional language related to recognising diversity and ensuring the cultural safety of children.

We’ve also applied these principles to smaller revisions to our Template: Statement of Commitment to the Safety and Wellbeing of children.

In addition, we’ve incorporated these elements into our Policy: Safeguarding, which addresses risk and supports the safety of all vulnerable people. We are continuously reviewing our resources to ensure that they incorporate best practice. 

You can access these resources in the Reading Room by logging into your SPP account. 

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Important Disability Regulatory Reform Updates

Posted on by Aaron Banick

Efforts to support and protect the human rights of people with disability have been high on the government’s reform agenda since the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability handed down its final report and recommendations, and the Independent Review of the NDIS was completed in late 2023. As part of these broader developments, there will be significant changes to how the NDIS operates and is regulated. 

On 28 October 2024, the NDIS Quality and Safeguards Commission published its Regulatory Reform Roadmap for 2024-2025 which sets out the stages for reform, and when providers can expect changes to come into effect. It includes periods of consultation where providers and participants can provide feedback on the proposed changes. 

This ongoing process has no doubt also been top-of-mind for NDIS providers, who will want to keep up with changing requirements and continue to provide the best possible supports to participants. We are also hard at work, focused on helping providers with their compliance requirements and tracking the changes as they come through. 

Previous Developments

The Disability Royal Commission highlighted a number of areas of concern regarding the inclusion of people with disability in the broader community, and the protection of their human rights. In case you missed them, take a look at our previous blog posts that go over some key themes from the report and their implications for service providers:

First NDIS Amendment Act

The Government passed the National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No.1) Act 2024 (Cth) (the first of two NDIS amendment acts) on August 22, which went into effect in the beginning of October. The amendment changed how participants are assessed, the definition of NDIS supports, and outlined how participants can use their funding. Summaries of these changes can be found on the NDIS website. 

Disability Employment Program Reforms

The Department of Social Services has been progressing its replacement of the current Disability Employment Services program with the New Specialist Disability Employment Program, which will commence on 1 July 2025. The new program will seek to increase eligibility and be more adaptable to individual participant circumstances. More information can be found on the DSS website. The tender period will be closing shortly. Additional information regarding the program will be made available closer to commencement. 

Upcoming Changes

Recently announced details of upcoming reforms indicate significant changes to how NDIS providers will be regulated. Additional examination will occur when the Government publishes their response to the NDIS Review, which is expected to be made available in December 2024. 

Mandatory Registration

Additional categories of disability service providers will be subject to mandatory registration with the NDIS Quality and Safeguards Commission. Provider types which will be required to register will include:

  • Platform providers;
  • Supported Independent Living (SIL) providers; and
  • Support coordinators.

These organisations will be required to comply with the NDIS Practice Standards and meet ongoing audit requirements. Mandatory registration will commence no earlier than 1 July 2025. The Government commenced consultation on these registration changes on 31 October, and will be open to submissions until March 2025. 

Second NDIS Amendment Act

The second NDIS Amendment Act will be introducing increased regulatory powers for the NDIS Quality and Safeguards Commission. Proposals for the new amendment include:

  • Increasing the penalties for providers when a participant suffers harm under care;
  • Subjecting providers to stronger penalties and criminal proceedings for serious failures to comply with registration conditions; and
  • Generally strengthening the Commission’s ability to gather information and impose bans on individuals within all areas of the NDIS.

The government will be consulting with stakeholders across the disability service system about the proposed changes. The second Amendment Act will be considered by parliament no earlier than March 2025.

Review of NDIS Practice Standards & NDIS Rules

As part of the reforms, the NDIS Practice Standards and NDIS Rules will be reviewed and strengthened. At this stage we understand that consultation on changes will begin in March 2025.

What We're Doing

We are monitoring developments and will be updating our resources to reflect the most recent information as it becomes available. We’ve already updated many of our existing resources and created new resources in response to the major themes in the final report of Disability Royal Commission, including safeguarding, human rights, and access and inclusion.

We will also help providers understand any changes proposed to the NDIS Practice Standards when they are released, by building new self-assessment modules. 

Make sure you’re subscribed to our emails and newsletters, as we’ll keep you updated!

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Spotlight on Board Governance

Posted on by Aaron Banick

The Aged Care Safety and Quality Commission’s Sector Performance Report for the quarter to June 2024 provided a year-in-review summary of the state of standards compliance within the aged care sector. 

The report found that Quality Standard 8 (Organisational Governance) had the lowest rates of compliance throughout 2023-2024. What’s more, this standard had the greatest difference in compliance levels between residential services and home care, where the latter was assessed at only 70% compliance. The Commission has therefore signalled an increased focus on organisational governance, where they say some aged care providers are falling short. 

The Commission’s findings echo conclusions of the Royal Commission into Aged Care Quality and Safety and the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability, which both found that boards and governing bodies often lack the knowledge and professional skills necessary to establish effective organisational governance systems. 

Examples given included lack of:

  • basic functional capabilities,
  • fundamental gurantees of independence and transparency, and
  • any representation of professionals in aged care delivery or experts in clinical care.

These findings prompted significant “provider governance” reforms to the Aged Care Act in late 2023, which included stricter requirements for governing bodies to appoint qualified and independent board members, including a minimum of one member with clinical expertise. The provider governance requirements will also form an important part of the new Aged Care Act. You can read more about these changes in our blog post Preparing for New Age Care Provider Governance Requirements which discussed the additional requirements for providers to form advisory bodies, maintain staff qualifications and clinical governance.

Governance in the Spotlight

Governance is the fundamental means by which an organisation ensures it has the right capabilities and processes to provide the care services that the community needs. For this reason, requirements for responsible organisational governance are a core component of virtually all community and health service standards across the country. Inadequate governance can contribute to weak organisational culture, inconsistent practices and processes, and a lack of accountability, and this can increase the potential for substandard care and incidences of abuse and neglect.

Quality governance begins with the board, whose members work together to establish the culture, values and strategy which allow the organisation to meet its goals and help those who need it most. The overall success of the organisation depends on conscientious board members with the right mix of skills and experience to oversee how the organisation is managed.  This includes ensuring that it complies with its legal responsibilities and obligations, including all of the standards that apply to the services it delivers. 

How SPP can help

Our Standards & Performance Pathways (SPP) platform has a deep pool of resources to help boards develop strong governance systems, to deliver best-practice care to the community.  Here are just a few examples:

  • Culture and Values

The governing body and organisation leaders are responsible for establishing the ethics, values and standards of behaviour which form the basis of the organisation’s culture.

An organisational culture which promotes safety, inclusion and open dialogue with stakeholders helps to promote effective care. Members of the governing body should be fundamentally committed to the protection of human rights, and to championing and upholding the values of the organisation. The governing body is responsible for instituting policies to support these aims, including establishing codes of conduct which promote ethical professional practice. 

Find our Good Practice Guide: Purpose and Values in the Reading Room for a practical guide for developing a strong organisational culture. You can also find a range of useful templates to support your governance efforts including our Policy: Professional Ethics and Conduct, and Policy: Purpose and Values. 

  • Independence, Accountability and Transparency

Each member of the governing body has a legal duty to act in good faith, and to make decisions in the best interests of the organisation. This means boards must take an active interest and adopt policies which prevent members from making improper use of their position, and be truthful, transparent and accountable when making decisions.

It is a responsibility under the Code of Conduct for Aged Care that key personnel (which includes governing members) let the organisation know if there are concerns about their suitability to meet expectations of transparency. This includes avoiding, reporting and managing conflicts of interest. Boards should seek to implement best-practice policies including majority independent membership and commit regular review to assess the effectiveness of their governance systems to maintain accountability. 

 You can read more in the Reading Room, with helpful resources including our Good Practice Guide: Accountability and our Policy: Role of Governing Body Members, and Policy: Conflicts of Interest. 

  • Risk and Incident Management

The governing body is responsible for implementing strategies to identify, assess and treat risks that face the organisation. This helps to support the organisation to make informed decisions about how to address uncertainty in the operating environment, and to avoid oversights which can lead to harm. 

Part of this process involves active consultation and engagement with a range of stakeholders, particularly from people receiving care through structured feedback mechanisms. This should be regarded as an essential and ongoing process for leaders to understand how the organisation is going, and to address complaints about quality or safety through commitment to continuous improvement. 

 See our Good Practice Guide: Risk Management for an outline of useful resources, and our Policy: Client Feedback, and Policy: Complaints Management for practical information regarding gathering feedback, as well as our Policy: Partnering with Clients for an outline of approaches to incorporating service users into the service development and improvement process. 

  • Developing the right skills

Ensuring that members of the governing body have the right mix of skills, experience and expertise should be a key priority. Boards which lack vital professional knowledge and skills in aged care and clinical care, or otherwise overemphasise financial indicators of performance, can neglect indicators of safety and quality, allowing substandard care to go undetected and increasing the risk of incidences of serious harm. It is important that governing body members commit continuous effort towards development of professional skills and practical expertise relevant to effective organisational governance.

Organisations should put in place systems to make sure they are recruiting board members who are qualified, with valuable skills that will support effective governance. We discuss this within our Good Practice Guide: Board Recruitment. New members of a governing body should be actively supported throughout their orientation, so that their skills and experience can be focused on achieving organisational aims as quickly as possible. Take a look at our Board Orientation Kit for a detailed walk-through of how to introduce a new board member to your organisation’s processes and approach to its service delivery.

In the Reading Room you can find our Template: Board or Management Committee Skills Audit which provides a practical resource for identifying knowledge and skill gaps. Our resources, Info: Board or Management Committee – Skill Development, and Policy: Training and Development for Board Members can support the organisation to establish policies for training board members. The Aged Care Quality and Safety Commission also provides the Governing for Reform in Aged Care Program as a centre of excellence for improving skills in clinical and corporate governance. 

  • Regular supervision of key issues

It’s vital that boards implement a regular management reporting structure, including review and discussion of detailed KPIs of quality and safety.  We also have some great resources to assist in this area. See our Board or Management Committee: Good Practice – Governance and Management for a good starting point, and our Board Meeting Template for a detailed standing list of matters to consider and report on at meetings.

Towards Best Practice in Board Governance

The outcome of the Royal Commissions and recent sector performance data reiterate that more must be done to improve the performance of governance systems. It is essential that the governing body ensures that an organisation’s culture and systems align with their missions and goals, as an ethical responsibility to ensure that people who are in need get the support they require. 

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Spotlight on Antimicrobial Use in Aged Care

Posted on by Aaron Banick

A recent report on the use of antimicrobials in the community published by the Australian Commission on Safety and Quality in Health Care found that, while the overall use of antimicrobials in the Australian community has reduced over time, the dispensing of antimicrobials for residents of aged care homes and people over 65 is actually trending up.

What are antimicrobials?

Antimicrobials are medicines that are used to treat, prevent, and control a broad range of infections and infectious diseases, by inhibiting or destroying the bacteria, viruses or fungi that cause the infection.

The risk with over-use of antimicrobials is that antimicrobial resistance can occur. This happens when bacteria, viruses, fungi and parasites no longer respond to the antimicrobial medicines, lessening their effectiveness at fighting infections and therefore increasing the risk of severe illness, disability and death.

Antimicrobial resistance is accelerated when antimicrobials are unnecessarily or improperly used. This can result in negative effects across the entire health system, by increasing the likelihood of resistant infections and increasing the risk of other important health procedures including organ transplantation, major surgeries, and chemotherapy.

Enhanced risk for older people in care homes

Older people residing in care homes are at advanced risk off microbial infections, due to a few factors including:

  • They may have more than one medical condition affecting them (i.e. comorbidity);
  • Compromised immunity; and
  • The increased risk of exposure to infections due to frequent contact with staff, visitors and other residents.

Because older people are more at risk of infection, there is an enhanced risk that they may be prescribed antimicrobials inappropriately or unnecessarily. 

The Report

The Commission’s report, Antimicrobial use in the Community: 2023, draws from national prescription records between 2015 and 2023. The report found that the number of antimicrobial prescriptions in the general community between 2022-2023 remained roughly steady, at about 24% of the amount in 2015. However, this general downwards trend has not been reflected among older people, particularly residents of aged care homes.

Between 2022-2023, there was an 11.1% increase in overall antimicrobial prescriptions among residents of aged care homes. Nearly three quarters of residents received at least one antimicrobial prescriptions, which is well above the average of one-third for the general community. Older people living in care homes were also much more likely to be given broad-spectrum antimicrobials, even when they were not recommended for common infections.

Antimicrobial Stewardship

The report notes the critical importance of curbing the unnecessary or inappropriate use of antimicrobials through a dual strategy — preventing infections through minimising risk of transmission, and through promoting antimicrobial stewardship (AMS). 

AMS represents an ongoing effort by a provider to implement policies and processes which optimise and minimise the use of antimicrobials, to reduce the risks associated with increasing antimicrobial resistance.

AMS in the context of standards

Instituting best-practice AMS policies and procedures is a requirement of several sets of standards within the health and aged care sectors:

  • Health Services:
The Australian Commission on Safety and Quality in Health Care has included antimicrobial stewardship provisions within Standard 3 (Preventing and Controlling Infections) of the National Safety and Quality Health Services Standards, as well as within the related Antimicrobial Stewardship and Sepsis Clinical Care Standards.
 
AMS is also a requirement within the National Safety and Quality Mental Health Standards for Community Managed Organisations (Action 3.35), and the National Safety and Quality Primary and Community Healthcare Standards (Action 3.14). 
 
And AMS policies are relevant to compliance with the Royal Australian College of General Practitioners’ Standards for General Practice (Criterion GP4.1), which includes RACGP guidance for general practitioners on reducing risk of infections. 
  • Aged Care:

 The Aged Care Quality and Safety Commission has included antimicrobial stewardship within Standard 3(g) – (Minimisation of infection-related risks) of the Aged Care Quality Standards, and AMS also features prominently in the new Strengthened Aged Care Quality Standards under outcome 5.2 (Preventing and Controlling Infections).

The Commission advises aged care providers to implement best-practice processes and systems for monitoring antimicrobial use, to identify when prescriptions fall outside of recommended guidelines, and ensure that staff are educated on antimicrobials, including their responsibilities regarding antimicrobial stewardship. Additional information and resources can be found on the Aged Care Quality and Safety Commission’s website, including their antimicrobial stewardship self-assessment tool.

SPP Resources

Self-assessment modules to track compliance 

SPP provides a range of self-assessments for the standards mentioned above, to help you understand and track your compliance with their particular indicators or requirements regarding antimicrobial stewardship.

Policy templates to help implement procedures 

In addition, in SPP’s Reading Room you can find our Policy: Antimicrobial Stewardship, which is a valuable introductory resource for developing effective antimicrobial stewardship procedures. Antimicrobial stewardship should be developed alongside strong medication governance procedures. Our Policy: Medication Management will assist in outlining some key considerations.

These resources are complemented by our information and policy documents regarding Clinical Governance, and our self-assessment based on the Aged Care Quality and Safety Commission’s guidance for Clinical Governance.

We are also hard at work preparing for the upcoming changes in the Strengthened Aged Care Quality Standards so we can continue to support your efforts to deliver high quality aged care.

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