The new Aged Care Act, commencing 1 November 2025, introduces comprehensive reforms that place greater emphasis on transparency, accountability and governance.
One significant change is the requirement for Registered Providers to take responsibility for the conduct and compliance of their Associated Providers.
Associated Providers – whether allied health professionals, transport operators, catering companies or cleaning contractors, are often central to the delivery of aged care services. Under the new Act, providers can no longer treat these third parties as ‘separate’.
Registered Providers’ Responsibility
Section 11(6) of the Aged Care Act makes it clear that Registered Providers remain accountable for ensuring that services delivered by Associated Providers meet all applicable obligations.
This includes compliance with the Aged Care Quality Standards, the Aged Care Code of Conduct and requirements relating to screening, training, incident management and record keeping.
The Act also introduces a Statement of Rights, which outlines the entitlement of people accessing aged care services. These include the right to independence, choice, safety, respect and culturally appropriate care. All providers must ensure that all services delivered are consistent with these rights.
In practice, this means that Registered Providers must establish robust systems to monitor, support and verify Associated Providers. Without strong oversight systems, Registered Providers face risks – including non-compliance, regulatory penalties, reputational harm and most importantly, compromised safety and wellbeing for older Australians.
The Compliance Challenge
Managing compliance across a diverse range of Associated Providers can be complex. Associated Providers are subject to a broad range of legislative and regulatory requirements under the new Act, including:
- Workforce screening, training and supervision
- Feedback, complaints and whistleblower protections
- Incident management protocols and escalation pathways
- Record-keeping obligations, including vaccination data and worker credentials
- Notification requirements to the Aged Care Quality and Safety Commission
- Pricing transparency for user-sourced services
Clear legal requirements are the starting point, but building a cohesive culture of shared responsibility and continuous improvement is where lasting change happens. Registered Providers should view Associated Providers as partners in delivering safe, high-quality care – moving beyond mere compliance to build a culture of shared accountability.
Practical Tools for Oversight
To assist Registered Providers in navigating these reforms, we have developed a package of new resources:
1. For Registered Providers – Associated Provider Compliance Checklist
This is a high-level checklist designed to help Registered Providers undertake due diligence about the compliance position of each of their Associated Providers.
It clarifies the systems and processes each Associated Provider must have in place and acts as a communication bridge, fostering shared responsibility and continuous improvement.
It helps you to record that you’ve made enquiry and satisfied yourself about the processes each Associated Provider has put in place covering the topics summarised above in our self-assessment.
We’ve included hyperlinks to the relevant requirements of the Act and Rules throughout the checklist, to help you understand the context of each item.
2. Self-Assessment: Associated Compliance Attestation:
To make this process even easier, we have also developed an SPP module specifically for Associated Providers to complete. The module mirrors the Associated Provider Compliance Checklist and is designed to:
- Help Associated Providers assess their own compliance and confirm that they understand the core requirements under the Act and Rules directly within the SPP platform
- Enable structured self-assessment linked to relevant evidence and documentation
- Generate a compliance report and package up copies of core compliance documents, that can be submitted to Registered Providers, supporting transparency, consistency and ease of oversight
Our self-assessment contains the following modules:
- Associated Provider Details
- Workforce Requirements
- Incident Management
- Feedback and Complaints Management
- Whistleblowing
- Monitoring and quality assurance
- Record-Keeping
- Compliance Documents
We’ve included hyperlinks to the relevant requirements of the Act and Rules throughout the modules, to help you understand the context of each item.
3. Associated Provider Agreement
A practical contract template that formalises the relationship between Registered Providers and Associated Providers. It ensures:
- Clear articulation of roles, responsibilities and compliance expectations
- Alignment with the Aged Care Code of Conduct and Quality Standards
- A contractual basis for monitoring feedback and corrective action
Towards Best Practice
Associated Provider management is no longer a secondary issue – it is now an integral part of aged care governance. The reforms make it clear that providers are accountable for every part of the care ecosystem, even when delivered through third parties.
By adopting the available resources, providers can shift from risk awareness to risk readiness – strengthening not only their governance but also the safety and quality of care for older Australians.
You can find the new self-assessment for Associated Providers in SPP under the Standards tab > Aged Care – towards best practice or just search “Associated Provider” in the search bar.
You can find the Checklist and the Template Agreement resources in SPP’s Reading Room by searching the name of each resource – or just search “Associated Provider” to find both.
Please contact us at team@bngonline.com.au , or phone 02 9569 1704 if you have any queries.
