Get ready for the revised Aged Care Quality Standards

Reforms to the aged care sector continue, with the recent release of a consultation draft of the revised Aged Care Quality Standards (‘Quality Standards’). The new Quality Standards have some key differences compared to the existing standards – they are significantly more detailed, and represent a move away from the higher-level approach of the existing standards. There is definitely a lot for providers to take in, so let us help you get up to speed with our overview of the key changes.

Why are the Quality Standards changing?

The Royal Commission into Aged Care Quality and Safety found that the existing Quality Standards are not sufficiently ‘comprehensive, rigorous and detailed’.

The Royal Commission identified specific areas of improvement for the Quality Standards, including the need to:

  • reflect the needs of people with dementia;
  • better recognise diversity and improve cultural safety for Aboriginal and Torres Strait Islander people;
  • strengthen requirements in relation to governance and human resources;
  • describe more detailed requirements relating to food and nutrition; and
  • improve clinical care.

The revisions to the Quality Standards were also informed by engagement with the sector, an independent review, and comparison with existing standards for health care and disability support – the National Safety and Quality Health Service (NSQHS) Standards, and the NDIS Practice Standards.

What will the new Quality Standards look like?

Standard 1: The Person

Standard 1 focuses on important concepts including dignity and respect, older person individuality and diversity, independence, and culturally safe care.

The new Standard 1 remains fairly similar to existing Standard 1: Consumer dignity and choice in the current Quality Standards, with a focus on the older person.

Outcomes

  • Person-centred care
  • Dignity, respect and privacy
  • Choice, independence and quality of life
  • Transparency and agreements

Standard 2: The Organisation

Standard 2 is intended to hold the governing body responsible for fulfilling the requirements of the Quality Standards and delivering safe and quality care. Standard 2 goes into more detail than the current standards by itemising more requirements for systems that providers should have in place (including requirements regarding partnering with older people, accountability and quality systems, workforce planning, and emergency and disaster management).

Outcomes

  • Partnering with older people
  • Quality and safety culture
  • Accountability and quality systems
  • Risk management
  • Incident management
  • Feedback and complaints management
  • Information management
  • Workforce planning
  • Human resource management
  • Emergency and disaster management

Standard 3: The Care and Services

Standard 3 describes the way providers must deliver care and services. It sets out more detailed requirements regarding how providers assess each older person’s needs, goals and preferences, document this in a care plan and use this to inform the way care is delivered. Standard 3 includes a new requirement that providers implement a system for caring for people living with dementia.

Outcomes

  • Assessment and planning
  • Delivery of care and services
  • Communicating for safety and quality
  • Coordination of care and services

Standard 4: The Environment

Standard 4 focuses on the physical environment, which must be clean, safe and comfortable and enable freedom of movement for older people. Standard 4 also sets out requirements regarding infection prevention and control systems.

Outcomes

  • Environment and equipment at home
  • Environment and equipment in a service environment
  • Infection prevention and control

Standard 5: Clinical Care

Standard 5 describes the responsibilities of providers, with respect to the delivery of clinical care. Standard 5 articulates more detailed and technical requirements for clinical care compared with the existing standards, including in areas such as technical nursing, advance care planning, continence, falls and mental health. This standard was developed by the Australian Commission on Safety and Quality in Health Care, and aligns with the NSQHS Standards.

This standard will apply to providers delivering clinical care, whether it is in an older person’s home or a residential environment.

Outcomes

  • Clinical governance
  • Preventing and managing infections in clinical care
  • Medication safety
  • Comprehensive care
  • Care at the end life

Standard 6: Food and Nutrition

Standard 6 sets out requirements regarding what older people can expect of the food and drink they are provided in residential care services. It includes the requirement that food and drink is appetising, nutritious and safe, and that the dining experience is enjoyable. Having a dedicated standard for food and drink is a new development, and represents a greater focus on this area.

Standard 6 will apply only to residential care services.

Outcomes

  • Partnering with older people on food and nutrition
  • Assessment of nutritional needs and preferences
  • Provision of food and drink
  • Dining experience

Standard 7: The Residential Community

Standard 7 is about the residential community, and focuses on continuity of care, security of accommodation, and strategies to help older people maintain relationships.

Standard 7 will apply only to residential care services.

Outcomes

  • Daily living
  • Planned transitions

Other noteworthy changes

  • Use of the phrase ‘older person’/’older people’ – The term currently used to refer to a person receiving services under the existing Quality Standards is ‘consumer’, however the Aged Care Quality and Safety Commission acknowledges that this term is not generally well-received by older people. The new term used throughout the revised Quality Standards is ‘older person’.
  • More requirements, that are more detailed – The current Quality Standards are outcomes-focused and consist of eight standards, which include a consumer outcome, an organisation statement and a number of requirements. The new Quality Standards describe more detailed expectations for providers, with an increase from 42 requirements to 31 outcomes with 142 supporting actions. This may look like an increase in the regulatory burden for providers, but the intention is to provide greater clarity to providers, by being more specific about how to achieve the outcomes laid out in the Quality Standards.

Similarities with NDIS Practice Standards

The updated Quality Standards will align structurally with the NDIS Practice Standards, by following a ‘modular’ format and using outcomes and actions (called ‘quality indicators’ in the Quality Standards). The two sets of standards don’t have identical content, but there are plenty of similar themes, and the same pieces of evidence may be used by a provider to satisfy outcomes across both sets of standards. For example, an organisation’s incident management policy may be used to demonstrate compliance with the incident management outcome across both sets of standards.

Government is also considering regulating providers through a registration model, similar to the NDIS Practice Standards. Employing a registration model means that, “requirements for market entry and ongoing provider responsibilities would be applied proportionately, based on the provider’s registration category. A provider’s registration category would be determined based on the types of care and services the provider is seeking to deliver and the risks associated with them”. This is similar to how the NDIS Practice Standards currently operate.

What does the rollout look like?

There will be some time before the new Quality Standards are up and running.

Currently, the Department of Health Aged Care is holding a public consultation process for the Quality Standards, and providers are invited to take part.

Following the public consultation, Aged Care Quality and Safety Commission will conduct a pilot of the new Quality Standards, to test an updated audit methodology for the Standards.

Providers can expect guidance materials and further updates on the revised Quality Standards in early 2023.

Looking for more information?

The Commission has released a number of helpful resources for the new Quality Standards, including both a summary as well as a detailed Consultation Paper, and a summary and detailed document setting out the new Quality Standards themselves.

To understand the intention behind the new Quality Standards, as well as what all of the requirements are, you might like to take a look at the Commission’s Summary Consultation Paper, as well as the Summary draft of the Quality Standards.

Do you need assistance meeting the Aged Care Quality Standards?

Why your organisation should publish resources in Easy English

Many organisations can benefit from making key policies and procedures available in Easy English format. What is Easy English and why is it relevant for your organisation? Read on to find out.

What is Easy English?

Easy English is an accessible format, that uses images and simplified language to convey information. Easy English allows information to be understood by a broad range of audiences.

Easy English documents are particularly helpful for individuals with intellectual disability, but all kinds of organisations can benefit from introducing Easy English resources. The Easy English format is ideal for anyone who has difficulty reading and understanding written English, which can include people for whom English is a second language and people with lower literacy levels.

Why should your organisation develop Easy English resources?

Many service standards require key policies and documents to be made available to clients in a number of formats, and also require that clients understand their rights and responsibilities under these policies.

Making policies available online and in person is a great first step, however policies are often wordy and complex, meaning they are not truly accessible to clients with lower literacy levels. According to a 2011-12 study, around 44% of Australians have low levels of reading literacy. Creating Easy English versions of key policies and documents can help ensure that important information is available to everyone.

Tips for implementing Easy English materials

The Easy English writing style follows some important principles. Here are some key pointers to get you started:

  1. Keep sentences short.
  2. Try to explain one idea per sentence.
  3. Use everyday language and basic grammar.
  4. Use subheadings, bullet points and white space to break up the text.
  5. Use a simple font and layout.
  6. Use a large text size.
  7. Choose images that are easily understood and add meaning to each point.
  8. Include a definitions section for any complex words used in the document.

Some clients will be able to read and understand Easy English resources independently. Other clients may need some assistance from staff to read and understand the information.

How we can help

A number of Easy English policies and templates are available in the SPP Reading Room. These include:

  • Policy: Client Rights (Easy English)
  • Policy: Incidents (Easy English)
  • Policy: Incidents (Easy English) (NDIS)
  • Policy: Complaints (Easy English)
  • Policy: Privacy (Easy English)
  • Template: Emergency and Disaster Management Plan (Easy English)
  • Template: Child Rights (Child English)

Please contact us at team@bngonline.com.au, if you have suggestions or requests for Easy English resources you would like to see in the Reading Room.

Looking for Easy English templates?

The draft Aged Care Code of Conduct is here

As part of a recent suite of reforms set out in the Royal Commission Response Act, the Department of Health and Aged Care is introducing a Code of Conduct for Aged Care. An exposure draft of the Code has been released, and the Code will come into effect from 1 December 2022.

So, what does this new Code mean for providers and their workers? And how can you prepare for this new requirement?

An overview of the Code

We’ve been keeping close to developments relating to the Code, and aim to keep our customers up to speed as the Aged Care Quality and Safety Commission publishes new information. Here are some key pointers:

  • The Code of Conduct has been introduced to “improve the safety, health, wellbeing and quality of life for people receiving aged care and to boost trust in services”.
  • It sets out standards of behaviours for approved providers, governing persons, workers, volunteers and contractors to ensure services are delivered in a safe, competent and consistent manner.
  • The policy intent for the Code is not to create new obligations for providers; but rather to focus on the protection of older Australians by setting out the suitable standards of care, and ensuring that there are consequences for poor conduct.
  • The Code will take effect from 1 December, and will apply to residential aged care, home care, and flexible care providers. The Code will not apply to Community Home Support Programme (CHSP) and National Aboriginal and Torres Strait Islander Flexible Aged Care Program (NATSIFACP) providers.
  • The Commission will be able to issue banning orders to aged care workers and governing persons who breach the Code – however, this measure will only be taken in the most serious cases of poor conduct.
  • The Code is in draft form but should be finalised in the near future.

Your responsibilities and how you can prepare

The responsibilities outlined in the Code are consistent with existing legislation, the Aged Care Quality Standards and the Charter of Aged Care Rights, as well as community expectations and consumer expectations. As an example, the Aged Care Quality Standards include concepts such as affording consumers dignity and respect, which feature in the Code.

The Code is also consistent with the NDIS Code of Conduct, which will be familiar to some providers who work across both the aged care and disability sectors. Both Codes have a strong focus on the individual’s right to receive quality care and share many of the same obligations.

Compared with the NDIS Code, the Aged Care Code does have additional requirements for treating people with dignity and respect, valuing diversity, and providing care, supports and services free from violence, discrimination, exploitation, neglect, abuse and sexual misconduct. These additional requirements address key concerns raised by the Royal Commission into Aged Care Quality and Safety. Whilst the Codes are very similar, they will be regulated separately.

The Aged Care Quality and Safety Commission has emphasised that the Code of Conduct does not create new obligations, in the sense that providers and workers delivering care in accordance with existing regulations should already be meeting the Code. However, there is one new responsibility providers should be mindful of in relation to the Code, and that is: providers must take reasonable steps to make sure workers and governing persons comply with the Code.

The Commission has made clear that providers need to ensure their aged care workforce (including employees, volunteers and contractors) understands and acts consistently with the Code. Some steps you can take to ensure your workforce is ready include:

  • ensuring that workers have read and understand the Code and relevant guidance;
  • ensuring workers undergo regular training and professional development that helps them comply with and uphold the Code;
  • ensuring workers understand the consequences of not complying with the Code; and
  • supporting workers to resolve concerns identified in relation to their compliance with the Code.

Next steps

Make sure you have familiarised yourself with the draft Code and have a plan to prepare your workforce.

For more detail on the Code, please access the draft Code of Conduct for Aged Care: Guidance for providers.

Looking for assistance managing your aged care obligations?

An update on the Child Safe Standards in each jurisdiction

Last year we provided an update on where each state and territory was at with their implementation of the National Principles for Child Safe Organisations (the National Principles). You can read about that here.

Many of the states and territories have since progressed with their implementation of the National Principles, so we wanted to provide an update on where each state and territory is at now.

New South Wales

In mid-2020 the NSW Office of the Children’s Guardian (OCG) released the NSW Child Safe Standards. The Standards align closely with the National Principles. Late last year the Children’s Guardian Amendment (Child Safe Scheme) Bill 2021 passed in NSW parliament. This Bill embedded the NSW Child Safe Standards as the primary framework guiding child safe practices in NSW.

The Bill came into effect on 1 February 2022 and requires a broad range of organisations who work with or provide services to children to implement the NSW Child Safe Standards. The bill provides the Children’s Guardian with powers to monitor the implementation of the Child Safe Standards. For more information on the child safe requirements in NSW, as well as an overview of which organisations are “child safe organisations” to whom the Standards apply, refer to our previous blog post on the changes to child safe legislation in NSW.  

Victoria

The new Victorian Child Safe Standards came into effect on 1 July 2022. They also closely align with the National Principles, however there is one additional Standard (Standard 1), concerning cultural safety for Aboriginal children and young people, and two additional indicators in Standard 3 around empowering children and young people. 

The Commission for Children and Young People (CCYP) works with co-regulators to regulate all organisations that must comply with the Standards. They have stated that their focus initially will be on informing and educating organisations about their obligations under the new Standards. From January 2023, the CCYP will expect organisations to have more comprehensively implemented the new Standards. See our previous blog post for more information on the Victorian Child Safe Standards.

Queensland

In December 2019, the Queensland Government began initial consultations in relation to the establishment of a child safe framework. The Government was considering their options for building a stronger legislative, policy and practice framework for child safe regulation.

Since then, the Department of Children, Youth Justice and Multicultural Affairs has aligned their policies and procedures with the National Principles. Their fourth annual progress report outlines that the actions for aligning their policies and procedures with the National Principles are planned for delivery or completion during 2022. At this stage, we’re not aware of any further update on implementing and regulating the National Principles in Queensland. 

South Australia

The National Principles for Child Safe Organisations have replaced the former South Australian Principles of Good Practice. The updated requirements began on 1 July 2021, and require all organisations developing child safe policies and procedures to:

  • Align these with the National Principles, and
  • Reflect the SA legislative context.

Organisations were previously required to lodge a compliance statement against the South Australian Principles of Good Practice.  The changes mean that in their next policy review process, organisations must ensure that their policies align with the National Principles.  

The Department of Human Services South Australia is responsible for the implementation of the National Principles and the monitoring of organisations’ compliance statements.

Tasmania

The Tasmanian Government has begun the process to implement child safe standards for their state. The Child and Youth Safe Organisations Framework will be a legislatively mandated framework comprised of child safe standards and a reportable conduct scheme. Their child safe standards will closely align with the National Principles, but will be adapted to the Tasmanian context where required. The Department of Justice Tasmania is responsible for developing the framework.

The process to develop and implement the Framework is expected to go for 3 years. The indicative commencement date of the Framework is 1 January 2024. More information can be found here.

ACT

We are not aware of any further developments in the ACT since our previous blog post.

In October 2019, the ACT Government decided to regulate the Child Safe Standards in the Territory and began the development of a scheme. Public consultation ran from November 2019 until February 2020. The Government stated that the language of the ACT standards would be similar to the National Principles, but would also take into close consideration the Victorian and NSW versions of the Standards.

The Government had planned to develop legislation during 2020, however they stated that due to the COVID-19 pandemic the Bill to introduce a Child Safe Standards scheme was delayed and would be rescheduled for introduction at a later date. For more information click here.

Western Australia

Western Australia currently has a voluntary approach to the implementation of the National Principles, focused on capacity building, led by the Commissioner for Children and Young People (CCYP), while options for legally requiring implementation are developed.

The Department of the Premier and Cabinet is leading the development of a system of independent oversight in partnership with key government agencies and the CCYP, which will include the monitoring and enforcing of the National Principles for organisations engaged in child-related work.

The Department of Communities is leading the implementation of the National Principles through a range of administrative and legislative levers such as funding agreements and regulatory frameworks. They are also providing support to government and non-government agencies to implement the National Principles in preparation for independent oversight.

In April this year, the Department of Premier and Cabinet published a consultation summary report. This gathered information on the current progress, awareness and barriers to implementing the National Principles. At this stage we are not aware of a specific timeline on implementation of the National Principles in WA.

Northern Territory

There are no general child safety standards currently in force in the Northern Territory. Territory Families operates the Quality Assurance Program, however this applies specifically to children in out of home care. The National Principles have been endorsed by the NT Government, but compliance is not monitored. The Northern Territory has not yet indicated a timeframe for implementing the National Principles.

How can SPP help me meet my child safe obligations?

We have self-assessment modules, policy templates and other resources, in SPP for the:

  • National Principles for Child Safe Organisations;
  • NSW Child Safe Standards; and
  • Victorian Child Safe Standards.

In partnership with Australian Catholic Safeguarding Ltd, we have also built self-assessment modules for the National Catholic Safeguarding Standards, which create a framework for Catholic entities to promote and ensure the safety of children and adults at risk.

We will be closely monitoring the progress of other states in their implementation of the National Principles, and we plan on adding new self-assessments for new standards that arise from the implementation process.

To access these self-assessments and all of our child-safe resources, log in to SPP.

Want to access our child safe self-assessments?

ISO self-assessments for community organisations

Over the last ten years or so, we’ve seen the emergence and continuing refinement of many comprehensive community and health services standards, at both the state/territory level as well as the national level.

These standards share common aims, the core of which are to:

  • educate and assist NFPs to implement more robust and consistent approaches to corporate governance and quality improvement processes; and, as a result,
  • improve the consistency, safety and quality of the services for their clients.

There are too many standards to name here, but they apply to a broad range of services such as:

  • aged care;
  • disability and mental health services;
  • primary, community and other healthcare;
  • homelessness services;
  • alcohol and other drug services;
  • domestic violence services; and
  • a wide range of services that are funded by state government departments.

While there are numerous areas of commonality across these standards, each has also been tailored to address the specific needs and requirements of the clients served in their particular sector.

Aside from these Australian service-specific quality standards which have developed and evolved over time, the International Organisation for Standardisation (ISO) has a suite of standards which are recognised globally as a benchmark of best practice across core thematic areas.

ISO’s standards are some of the most well-known and widely used standards in the world. While a large number of service streams in Australia are now mandated to follow the particular standards that apply to their service (or their funding agreement), many organisations continue to follow ISO standards, and in certain cases (for example disability employment services) they may be required to do so.

For this reason, we continue to support and add to our self-assessment modules for ISO standards, alongside the more than 100 other standards and best practice modules we now carry in our SPP platform. Here is a snapshot of what we have currently:

ISO 9001:2015 Quality Management Systems

These very well-established standards address continuous improvement, and are used across a range sectors. Since their release, many standards that are specific to the community and health services sector have incorporated the themes and requirements of ISO 9001. ISO’s Quality Management Systems standards are the backbone of ISO’s approach to their standards, as quality management is a central theme throughout their other sets of standards. ISO 9001 itself heavily prioritises the ‘Plan, Do, Check, Act’ cycle of continuous quality improvement, and requires organisations to implement continuous improvement processes throughout their operations.

ISO 45001:2018 Occupational Health and Safety (OH&S) Management Systems

This set of standards is about the documentation, implementation, operation and review of an organisation’s OH&S management system. It ensures that documented processes are in place to improve the health and wellbeing of the workforce, as well as addressing and eliminating hazards, risks and non-conformities. As ISO 9001 does, these standards also place an emphasis on review and continuous improvement.

ISO 27001:2013 Information Security Management Systems (ISMS)

In recent years, information security has become a more pressing issue for organisations, particularly those who are involved in the delivery of community services and, by extension, the management of client records. These standards are a good measure of best practice for organisations who are concerned about their information security systems. They help organisations to understand the primary risks to information security, and how to protect against those risks. Additionally, the Australian Federal Government requires ISO 27001 certification for all providers of employment skills training and disability employment services.

Coming soon: ISO 31000:2018 - Risk Management - Guidelines

We will shortly be adding a self-assessment module for ISO 31000. This set of standards helps organisations to understand and implement a best practice approach to risk management.

Want to access our ISO self-assessments?

SPP best practice modules – a foundational approach to good governance

Our SPP platform is well known for being a complete solution to standards compliance.  However, we also receive a lot of really positive feedback from users about how helpful they find our Towards Best Practice modules.

Many organisations use these modules to focus on good governance and continuous quality improvement across a range of operational areas of their business, separate from standards compliance.

Following requests from users, we’ve just released another Towards Best Practice module: Information Management and Privacy. This new module joins our other Towards Best Practice self-assessment modules, to help you address the important areas of:

  • Aboriginal and Torres Strait Islander Cultural Competence,
  • Continuous Improvement,
  • Finance,
  • Governance,
  • Human Resource Management,
  • Infection Management and Control,
  • Risk Management, and
  • Workplace Gender Equality.

These modules draw from the themes and indicators in a huge range of standards, to guide organisations through what best practice looks like in these key areas. The modules assist you to reflect on your current practices and processes, identify any areas for improvement and implement and track improvement steps over time.  

And what is really helpful, is that these self-assessments are all cross-mapped to the major mapped standards in our SPP platform. So, that means that as you complete the modules, you will simultaneously be making progress against the other major standards in SPP.

Where can I find these modules?

You can find all of these self-assessments in SPP on the Standards tab, under the ‘Towards Best Practice’ heading.

For more information on our Towards Best Practice self-assessments, refer to our previous blog post ‘What really is “best practice” and how do we achieve it?’.

Work towards Best Practice in SPP.

Surveillance technology and restrictive practices – what you need to know

The NDIS Quality and Safeguards Commission recently published a Practice Guide on the use of surveillance technology with respect to people with disability.

The Commission has observed that surveillance is commonly used, or proposed for use, for people with disability and in disability settings, primarily with the intention of ensuring safety, monitoring health, facilitating increased independence and preventing abuse and neglect.

However, there are a number of ethical and regulatory concerns associated with the use of surveillance technologies, thus prompting the Commission’s publication of the Practice Guide.

We’ve provided below an overview of the Commission’s guidance, as well as some important considerations for your organisation if you are thinking of using surveillance technology in your support settings.

What is ‘surveillance technology’?

Surveillance technology simply refers to any device which can record information about a person through electronic means. This can include:

  • CCTV cameras which capture audio and visual footage
  • Audio monitors
  • GPS devices which track a person’s location
  • Motion sensor alarms

When does use of surveillance technology facilitate the use of a restrictive practice?

While surveillance technology may be used by providers with the aim of preventing abuse and neglect, the Commission cites a number of studies which show limited evidence to support the effectiveness of the use of surveillance technology for this purpose.

Surveillance technology is not in and of itself a restrictive practice, however it may constitute a restrictive practice if its use has the effect of restricting the rights to freedom of movement of a person with a disability.

Under the NDIS Rules, the five regulated restrictive practices are seclusion, chemical restraint, environmental restraint, mechanical restraint, and physical restraint. The use of surveillance technology may be a regulated restrictive practice where it influences a person’s behaviour, stops them from accessing particular items or environments, or restricts their freedom of movement.

However, the use of surveillance technology is unlikely to constitute a regulated restrictive practice where it enables support or increases a person’s independence and freedom of movement.

The Commission provides as an example the use of a sound sensor that alerts staff when a person with disability who is at risk of falling and hurting themselves is getting out of bed. This would not be a regulated restrictive practice, as the device is being used to help staff to attend to the person and support them, and is therefore ‘enabling support’.

By contrast, if a sound sensor is installed on a fridge to alert staff to stop a person with disability from accessing food, this would constitute a regulated restrictive practice, as it is facilitating environmental restraint. Similarly, if an alarm is on a person’s door to alert a staff member to stop a person with disability from leaving their room, this would be a regulated restrictive practice, as it facilitates seclusion.

Providers should note that any use of surveillance technology that facilitates the use of a regulated restrictive practice must be clearly identified in a participant’s behaviour support plan, and authorised in accordance with relevant State or Territory requirements. See the Commission’s Regulated Restrictive Practices Guide for more information.

Right to privacy and meeting legal obligations

There are a number of ethical issues associated with the use of surveillance technology, not least the individual’s right to privacy.

Surveillance technology (CCTV in particular) can be very invasive and can compromise the personal privacy of a person with disability. The use of CCTV monitoring in a person’s bedroom is especially problematic and may give rise to criminal liability.

Legislation that must be considered in relation to surveillance technology includes State and Territory privacy laws, the UN Convention on the Rights of Persons with Disabilities and the NDIS Act 2013.

The NDIS Practice Standards also require that participants access supports that respect and protect their dignity and right to privacy. To meet the Privacy and Dignity Practice Standard, providers must:

  • Implement processes and practices that respect and protect the personal privacy and dignity of each participant.
  • Advise participants of confidentiality policies and ensure participants understand and agree to what personal information will be collected and why, including recorded material in audio and/or visual format.

Best practice considerations when using surveillance technology with people with disability

Human rights considerations should inform any usage of surveillance technology in the disability services context. Best practice usage of surveillance technology includes taking the following steps:

  • Adhering to any relevant privacy laws
  • Acting in the best interests of the individual, taking into account their preferences
  • Balancing safety and autonomy, including genuine involvement of the individual in discussions
  • Considering options for the individual to deactivate and reactivate the device, to allow them additional privacy, where possible
  • Considering who can access the recordings, where recordings are stored, and for how long
  • Considering the security of the surveillance technology in use
  • Regularly reviewing the use of surveillance technology to ensure it is the least intrusive option available
  • Where surveillance technology is facilitating the use of a regulated restrictive practice – ensuring it is thoroughly outlined in the participant’s behaviour support plan, and reviewed at least every 12 months, or as the participant’s circumstances change
  • Ensuring staff training goes beyond simple usage of the device, and includes legal and ethical considerations

Providers should be mindful that surveillance technology should never be used as a substitute for limited staffing or to save on costs; nor should it replace human contact, personal care or social interaction, leading to increased social isolation. Providers should also consider the limitations of surveillance technology, which can include faulty and unreliable devices, ineffective technology leading to delays in staff responses, and the potential for devices to be removed, damaged, forgotten or hacked.

For further detail on the matters discussed in the blog post, including a checklist for considering the use of surveillance technology, we suggest providers access the NDIS Quality and Safeguards Commission’s full Surveillance Technology Practice Guide.

For guidance on the NDIS Practice Standards, please access SPP/the NDS Quality Portal for self-assessments and helpful resources.

Access key resources on SPP.

How can you identify improvements in your aged care service?

The obligation to maintain compliance with the Aged Care Quality Standards (ACQS) is an ongoing journey that is shared across the organisation. Once you’re meeting the ACQS, the challenge is to not only continue demonstrating how you meet the standards, but to identify improvements.

To start off with, all staff members – from board members to part-time staff – should have a fundamental understanding of the ACQS.  This will not only help you work towards compliance, but also help you identify opportunities to improve your systems and processes and, as a result, improve the quality, safety and consistency of the services you deliver.  

We’ve developed a comprehensive package of self-assessment modules for the Aged Care Quality Standards for all aged care providers, from smaller home care providers or single residence operators through to complex multi-site providers.

Some of our modules are designed to help you better understand the detail and intent behind requirements, while others are designed to streamline your preparation for assessment contacts and internal reviews.  All of them provide access to our extensive library of linked templates and other resources. 

Aged Care Quality Standards - Self-Assessment Tool

This module is the simplest approach to demonstrating compliance with the ACQS, and aligns with the Commission’s self-assessment tool template. The module enables you to include:

  • A Self-Rating;
  • Examples of Actions and Evidence;
  • Areas for Improvement; and
  • Any Other Information that may be relevant.

Aged Care Quality Standards - Educative

Our educative module for the ACQS provides a detailed walk through the Standards. It draws on the Commission’s “examples of action and evidence”, and will help providers understand the intent of every requirement contained in the Standards.  The educative module is very useful for organisations wanting a deep dive into the Standards.

Aged Care Quality Standards – Full Standard

This module is cross-mapped to other sets of standards in our platform, so is best suited to providers who are required to meet multiple sets of standards. It mitigates the duplication between the ACQS and other leading standards such as the NDIS Practice Standards. As you complete work in the module, your answers and evidence will automatically map across to common requirements in modules for other standards. The cross-mapped module is a useful tool to identify areas of overlap, as well as gaps, between different standards.

Guidance for governing bodies

We have a separate Board Governance Toolkit available for governing body members of aged care providers. The Board Governance Toolkit assists governing body members to understand and manage their responsibilities as set out in the requirements of Standard 8 of the Aged Care Quality Standards. It includes a simple introductory video and summary of the indicators, to provide governing body members with an introduction to, and overview of, the ACQS requirements.

Clinical Governance

We also have a module to help providers develop and review their clinical governance framework. This module is based on guidance issued by the Aged Care Quality and Safety Commission. The module guides providers through the core elements of clinical governance, and outlines the roles and responsibilities of each stakeholder group that should be involved in the process. It helps providers identify any gaps and opportunities for improvement and meet their clinical governance obligations under the Aged Care Quality Standards.

Just released: 5 key risks in home care

We’ve just released a new module based on the Commission’s guidance regarding the key areas of risk identified in home services. This new module supports governing bodies and senior management teams to critically examine their performance against 5 key risk areas, to ensure that they meet their obligations and deliver safe and quality home services.  

Where should you start?

All of these modules can be accessed on the Standards tab, along with hundreds of other sets of standards. If you’re looking for anything in particular in our platform or would like to provide any feedback or suggestions, we’d love to hear from you! 

Contact us here.

Want to access our self-assessments for the Aged Care Quality Standards?

NDIS emergency and disaster management: What do providers need to put in place?

In response to the impact of COVID-19, as well as a number of recent natural disasters including bushfires and floods, the new NDIS Emergency and Disaster Management Practice Standard was introduced in November last year. This was one of three new NDIS Practice Standards that were introduced at the time.

It was added into the NDIS Practice Standards so that providers ensure they have measures in place that will enable the continuity of each participant’s critical supports in the event of an emergency or disaster.

Over the last couple of months, we’ve given a number of webinars on this new Practice Standard, and we’ve also been helping providers work through what processes and documentation they should have in place to meet its requirements.

For those who missed the recent webinars, we wanted to summarise the key takeaways here.

Key steps

There are a number of steps or processes that are core to this new NDIS Practice Standard.

Planning

As a part of the planning process, providers should consider:

  • the environment/context in which they deliver supports,
  • the supports they provide,
  • the individual needs, circumstances and risks of each participant and, in particular, which supports are critical to the participant’s daily living needs, and  
  • how they are going to ensure continuity of those critical supports for each participant in a disaster or emergency.

This involves developing and implementing plans at two levels:

Whole of organisation plan

The organisation as a whole must have an emergency and disaster management plan in place, and that plan needs to set out clearly how the organisation will adapt and respond to an emergency. It should identify the people who will be responsible for key roles, and what actions will be taken to ensure the continuity of operations and the delivery of critical supports. This plan must be communicated clearly to all stakeholders, including all workers, participants and their support networks.

Individual participant plan

Second, the organisation needs to include in each participant’s support plan the details of which supports are critical to that participant, and how those critical supports will continue to be delivered in a disaster or emergency situation.

That doesn’t necessarily mean an individual emergency management plan for each participant. But plans for the alternative delivery of critical supports do need to be identified and included in each participant’s risk assessment and support plan, so that the participant (and all relevant workers, carers and family members) understands whom they need to contact, who will help them and how, in the event of an emergency or disaster.

Consultation and communication

Providers must consult with participants, their carers and family members, to ensure the participant’s circumstances and individual needs are understood. This means understanding each participant’s living circumstances and anticipating how they could be impacted by an emergency or disaster.  It means having a clear understanding with them about things like whom to call first and what to do should an emergency occur, and what alternative arrangements the provider has put in place to support them. Providers must consider how to communicate with participants, their representatives and workers in an emergency. Providers should collaborate with other providers, swap experiences and learnings and integrate these into planning.

Training

Providers must conduct regular staff training, including refresher training. Workers need to know what the organisation’s plan involves, who the key personnel are, and what their own role is in an emergency or disaster. Providers should ensure that they are familiar with the individual circumstances of their workforce, for example whether there are staff who live alone or in low-lying areas that may be affected by natural disasters, so they can determine who will be more available to assist in various emergencies or disasters.

Review

Providers must frequently review the plans, to ensure that new information and learnings from actual experiences are used to adjust the plan. The organisation must test the plans and hold drills to ensure you are prepared. This includes continuously improving the plan and consulting with industry peers.

Governing body responsibilities

The governing body is specifically, personally responsible for ensuring that all key steps set out in the new NDIS Practice Standard are implemented and followed by their organisation. 

This includes ensuring that:

  • management develops its organisation-wide plan,
  • there is consultation with all participants and their support networks about their individual needs, risks and alternative support plans,
  • their plans are regularly reviewed and tested,
  • they are communicated to all stakeholders, and
  • that workers are trained in and understand the plans that are specific to the participants they support.

Our resources

We have a number of resources to assist providers to meet their obligations under these new requirements. These resources are linked throughout our assessment modules for the NDIS Practice Standards. You can also access them by searching for them in the Reading Room.

  • Policy and Template for Emergency and Disaster Management Procedures
  • Template: Participant Risk Assessment
  • Template: NDIS Support Plan
  • Template: Communications Plan
  • Policy: Infection Prevention and Control
  • Template: Outbreak Management Plan Checklists
  • Policy: Business Continuity
  • Template: Emergency and Disaster Management Plan (Easy English)

For a really detailed run-through, you can access our recent 22-slide deck by searching for “NDIS PS webinar” in the Reading Room once you log in.  And don’t forget to download our handy update on all of the new Quality Indicators added to the NDIS Practice Standards, which you can find on the Home Page.

Want to access our emergency and disaster management templates?