Aged Care Resource Roundup

Now that the Aged Care Act 2024 and Aged Care Rules 2025 are in effect, we thought it would be helpful to summarise all of our aged care related self-assessments and key resources, to remind you of the many ways SPP can help you transition into the new framework! 

Our Aged Care Self-Assessments

Over the last year or so we’ve added and updated a range of detailed self-assessments to help providers: 

  • Get on top of all of the new requirements 
  • Undertake gap analysis and create automatic improvement plans 
  • Access hundreds of comprehensive templates 
  • Package up compliance reports and required evidence 

Here’s a quick snapshot of the self-assessments available in SPP:

Strengthened Aged Care Quality Standards

Track compliance with all Outcomes and Actions of the Strengthened Aged Care Quality Standards, with our related templates, policies and info sheets linked throughoutYou can automatically transpose compliance reports and evidence straight into the Commission’s Audit Evidence Collection Tool (AECT). 

Aged Care Financial and Prudential Standards

Contains all requirements of the three new financial and prudential standards, with links through to our templates for: 

  • Financial and prudential management system 
  • Liquidity management strategy  
  • Investment management strategy 

Aged Care Act 2024 – Provider Obligations

We’ve built a comprehensive series of modules to help you understand and monitor your compliance with all of the core obligations and conditions of registration of providers within the Act and Rules.  

There are too many to list here, but our modules cover topics including: 

  • Responsible persons and suitability matters 
  • Governance requirements 
  • Workforce vaccinations 
  • Restrictive practices 
  • Incidents 
  • Complaints, Feedback and Whistleblower Disclosures 

Associated Provider Compliance Attestation

Associated Providers can use this self-assessment to confirm their understanding of their core obligations under the Act and Rules – as well as provide registered providers with required information and evidence of compliance. 

Registered providers can evidence their due diligence by having Associated Providers answer the questions in SPP or the Q&A report spreadsheet. 

AECT and CDECT Supporting Documents

Providers are using the self-assessments we’ve built for the AECT, as well as Care Delivery Evidence Collection Tools (CDECTs), to package up their Required Supporting Documents.  Of course, we’ve linked all of our relevant resources to each Required Supporting Document. 

Our members with multiple facilities are using these self-assessments to ensure that each of their facilities understands what documents they need to provide.  Each facility can then package up the appropriate mix of corporate documents together with facility-specific documents. 

Our Huge Range of Aged Care Quality Standards Resources

Did you know that we have over 165 resources in our Reading Room that are specifically linked to individual Actions under each Outcome of the Aged Care Quality Standards?

That long list includes templates, policies and checklists to meet requirements of the Act and the Quality Standards, including relating to: 

  • The Governing Body and Responsible Persons 
  • The Quality Care Advisory Body and the Consumer Advisory Body 
  • Associated Providers 
  • Person-Centred Care 
  • Choice, Independence and Decision-Making 
  • Partnering with Individuals 
  • Clinical Governance 
  • Comprehensive Care 
  • Safe and Quality Use of Medicines 
  • Reportable Incidents 
  • Feedback, Complaints and Whistleblowing 
  • Risk Management 
  • Safeguarding 
  • Safe Service Environment

Interested in learning more?

Reach out to us if you’d like to learn more about how SPP is helping hundreds of aged care providers transition into the new quality and safety framework! 

Please contact us at team@bngonline.com.au or call us on 02 9569 1704.  

Need help with Aged Care Compliance?

Sign up to SPP for everything you need to help you transition to the new framework.

From Risk to Readiness: Managing Associated Providers under the New Aged Care Act

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 
  • 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. 

Our New Suite of Cognitive Impairment Resources

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”. 

Interested in our cognitive impairment resources?

Sign up to SPP and access our complete suite of policy templates!

Spotlight on 2024

With 2024 coming to an end, it’s a great time to look back at some of the biggest changes and developments of the year in the community and health services sector. 

Aged Care

Following the release of the final draft Strengthened Aged Care Quality Standards in December 2024, this year the focus was on preparing for implementation, which will commence in July 2025.  We worked hard over the 2024 Christmas break and then released an updated self-assessment for those Standards in early January, to help providers understand and prepare for expected changes and new requirements. 

Throughout the year, we’ve been reviewing our suite of resources against the draft requirements to ensure they’ll be ready to support providers’ compliance when the new Framework comes into effect. From revising 19 resources to cover new evidence-based care requirements, to updating our safeguarding resources in light of SIRS changes, to releasing a new policy template on Personal Property, and using Aged Care Quality and Safety Commission Clinical Alerts to guide the development of a new Extreme Heat policy template, we’ve been working to ensure we’re ready to support your organisation.  We’ve also just recently updated and added to our Medication Management resources.

Disability

The findings and themes of the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability have continued to inform changes in the disability sector (and beyond) throughout 2024. Following on from our work in 2023 to revise and update our safeguarding resources to reflect the recommendations of the Disability Royal Commission, this year we worked to create new resources and review our existing resources to reflect other recommendations. Some highlights include our new Policy: Human Rights and Policy: Disability Access and Inclusion. 

We also updated our NDIS Code of Conduct self-assessment to reflect changes to the legislation, and built a new self-assessment designed for Disability Employment Service (DES) providers to help them comply with the DES Quality Framework. 

More recently, we published a blog post on the NDIS regulatory reforms and some of the changes in the Disability sector, summarising the themes of focus, the changes already made and expectations for changes yet to come. 

We will be closely monitoring the release of the consultation draft of the new NDIS Practice Standards and Rules in early 2025.

Healthcare

This year we’ve had an increased focus on building self-assessments under the National Safety and Quality Health Service (NSQHS) Standards umbrella. We worked in collaboration with some of our members to develop self-assessments for three of the Clinical Care Standards, to help healthcare providers meet their NSQHS obligations when delivering specific care supports in the following areas: 

  • Antimicrobial Stewardship; 
  • Delirium; and 
  • Psychotropic Medicines in Cognitive Disability or Impairment. 

Following their launch in late 2023, we also released new self-assessments this year for the National Consensus Statement for End-of-Life Care and National Safety and Quality Cosmetic Surgery Standards. 

State and Territory Self-assessments

The States and Territories have also been busy in 2024. Updates to major social services standards in Victoria (Victorian Social Services Standards replacing the Human Services Standards) and Queensland (Human Services Quality Standards) have resulted in changes to our self-assessments, while we’ve also been building self-assessments for more specialised state and territory Standards, such as the: 

  • ACT Children and Young People (Care and Protection Organisation) Standards, 
  • NSW Point to Point Safety Audit Tool, and the  
  • SA Injury Management Standards for Self-Insured Employers.  

Many of our specialised state and territory self-assessments have been built in consultation with, or following requests from, our members, directly supporting their compliance. If there’s a self-assessment for a particular set of Standards you’d like to see in SPP, let us know! 

A key area of focus for the States and Territories this year has been child safety and protection, with both Tasmania and Queensland introducing their Child Safe Standards to join the National Principles for Child Safe Organisations, and the Victorian and New South Wales Child Safe Standards in the platform. We’ve built self-assessments for all of those jurisdictions, and will be watching closely for the release of child safe standards in other jurisdictions in the year to come! 

Workplace Reforms

Another priority this year relates to working conditions for staff. Updates to the Fair Work Act 2009 have changed the way organisations assess a person’s status as a contractor or casual employee, and work to protect work-life balance through new right to disconnect provisions. We’ve updated our Policy: Contractor Management in response to these changes, and will be working on resources about the right to disconnect in the new year. 

In addition, we’ve continued work on expanding and improving our suite of Workplace Health and Safety resources, including a new Manual Handling Policy, reviewed Whistleblower Management resources for added requirements in the new Aged Care Act 2024, and a helpful spotlight on workplace safety covering key areas in WHS. 

Extra Features in SPP

We also made some exciting changes to the SPP platform during the year. In addition to our Board Governance Toolkit which launched late last year, we’ve now added an in-platform Risk Register tool, with an integrated Heat Map, to help providers manage risks across their organisation. 

We’ve also made improvements to our document search system, allowing members to search for resources in the Reading Room that match particular Standards, and in many cases individual requirements within those Standards, to streamline the search process and help providers match resources that are going to be of most assistance to the requirements they need to meet. 

Looking Forward to 2025

2024 was a busy year in the community and health services sector, and 2025 is already shaping up to be the same. Major legislative developments in both the Disability and Aged Care sectors have recently passed, heralding significant changes to these areas in the new year- and we will be here to help you navigate all the changes you need to know about in 2025.  

We’ll be taking some time to celebrate the holidays and the New Year, so our last day in the office for the year will be Friday, December 20 and we’ll be back on Monday, January 6, but if you need urgent assistance over that time, we’ll still be monitoring our inbox and we’ll get back to you as soon as we can! 

All of our best wishes over the holiday season!

Supported Decision-making and Dignity of Risk

In our blog post ‘DRC: Supported Decision-Making,last November, we explored the evolving landscape of Supported Decision-Making (SDM) within Australia’s disability sector.

SDM was a central theme in the Disability Royal Commission (DRC) findings, particularly in Volume 6, which underscored the vital need to empower people with disabilities to make their own decisions. Public Hearing 32 further emphasised the crucial role of service providers in safeguarding the autonomy and rights of people with disabilities, positioning SDM as a fundamental practice for protecting individual freedoms and ensuring people have the agency to make choices about their lives.

A year on, we are revisiting the topic to reflect on the considerable progress that has been made and the growing attention it has received in a number of jurisdictions, including:  

  • the National Disability Insurance Scheme (NDIS),  
  • the Aged Care sector,
  • the Australian Commission on Quality and Safety in Health Care, and
  • the Victorian social services sector. 

NDIS

The National Disability Insurance Agency has incorporated SDM principles into its guidelines and information sheets, providing essential support to assist providers in empowering participants to make their own decisions.  

This includes ensuring that providers are aware of how to offer people with disability a range of options to express their preferences, provide assistance in understanding and weighing choices, and ensure that their decisions are respected. 

Aged Care

It is also important to consider the increased emphasis on SDM within the Australian Aged Care sector, particularly following the recommendations from the Royal Commission into Aged Care Quality and Safety. One of the significant changes in this area is in the Strengthened Aged Care Quality Standards, which will come into effect in July 2025, and which place a stronger focus on empowering older Australians to make decisions about their care, in line with the principles of SDM. 

Standard 1, The Person, is especially relevant, as it focuses on concepts such as dignity and respect, older person individuality and diversity, independence, choice and control, culturally safe care, and dignity of risk. In doing so it requires providers to support older people to make informed decisions about their care and daily lives.  

This includes actively involving individuals in decisions regarding their care preferences, ensuring that they have access to the information and resources needed to make those decisions.

Healthcare

The Australian Commission on Quality and Safety in Health Care has embedded SDM into its quality standards, with a strong emphasis on safeguarding the rights of people with disability.  

A key document that reinforces this commitment is the NSQHS Standards User Guide for the Health Care of People with Intellectual Disability. This guide highlights the importance of respecting the autonomy of individuals by facilitating supported decision-making in healthcare settings. It aligns with Standard 2: Partnering with Consumers of the National Safety and Quality Health Service (NSQHS) Standards, which stresses the need for healthcare providers to involve patients in decisions about their care. Service providers should ensure that they adopt SDM principles as part of person-centred care, ensuring individuals with intellectual disabilities have a voice in their treatment options, and that their choices are respected throughout their healthcare journey. 

Victorian Social Services

An example of the broader adoption of the principle of SDM across other sectors is its inclusion within the new Victorian Social Services Standards, which came into effect in July 2024.  

These standards apply to a wide range of Victorian social services providers, including child protection, family violence, homelessness, out-of-home care, and sexual assault services. Within the standards, significant emphasis is placed on promoting the autonomy and independence of service users, particularly in Standard 2, ‘Service User Agency and Dignity’. The standards encourage service providers to develop practices that cultivate a culture of respect, ensuring individuals have a meaningful voice in the decisions that affect their lives. 

Looking Ahead: Continuing Progress

At BNG, we are committed to supporting service providers to further embrace SDM practices and dignity of risk. We’ve recently reviewed our resources related to supported decision-making including:  

  • Info: Supported Decision-Making (Easy English)  
  • Policy: Supported Decision-Making and Dignity of Risk  
  • Policy: Supported Decision-Making and Dignity of Risk (NDIS)  

We hope that by continuing to share resources, insights, and examples of best practice, we can contribute to the ongoing effort to ensure that all Australians can make their own decisions and lead lives that reflect their values and aspirations.  review

Ready to get started?

Sign up to SPP and let us support your organisation’s Supported Decision-Making processes!

Spotlight on Board Governance

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. 

Looking to improve your governance systems?

Sign up to SPP and let our Board Governance resources guide you towards continual improvement!

Spotlight on Antimicrobial Use in Aged Care

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.

How is your organisation supporting AMS?

Sign up to SPP and let our antimicrobial stewardship resources guide you towards compliant processes!

Tracking compliance with the Aged Care Quality Standards

The Aged Care Quality and Safety Commission’s recently published Sector Performance Report for the March 2024 quarter provides some key insights into a number of areas of focus for the sector, where targeted improvement will result in improved experiences of older people receiving aged care.  

Overall, while 84% of residential aged care providers were found to be fully compliant with the current Aged Care Quality Standards, only 64% of home care providers were compliant with all eight of the Standards. The two lowest levels of compliance were for Standard 2 – Assessment and Planning and Standard 8 – Organisational Governanceand the Commission also signposted an increased focus on the food and nutrition component of Standard 3 – Personal Care and Clinical Care.  

Whether your organisation is compliant or not, it’s helpful to stay up to date on areas of focus, and regularly review your processes to ensure that older people are receiving the best possible care from the services you provide.  

Preparing to deliver care – Standard 2

Assessment and planning requirements make up a large proportion of non-compliance with the Quality Standards, across both home care and residential aged care services.  

Compliance with Standard 2 is a particular issue of concern in home care. Over one-third of home care providers were found to have compliance issues relating to Standard 2, particularly in the area of assessment and planning. Assessment and planning processes are especially important for home care providers, as the provider and staff have less control over the service environment, and may only provide services to, or even have contact with, each older person at limited times. Working with each older person and their family to put in place a care plan that works for them within their home environment is essential forhigh-quality home care.  

Other issues of concern to the Commission across both residential and home care providers relate to risk management, especially failures to consider risks to safety and wellbeing when planning services, and failures to reassess and review risks when circumstances change or an incident occurs.  

For those interested in risk management, we’ll be publishing a more in-depth look at how risk management can support your organisation’s processes soon. 

Governance processes supporting compliance – Standard 8

Three of the ten lowest levels of compliance with the Quality Standards fall under Standard 8, which is concerned with organisational governance requirements.  Compliance with Standard 8 is a continuing major focus area for the Commission, as organisation-wide governance systems, risk management systems, and clinical governance frameworks underpin the delivery of quality and safe care to older people.  

Governance requirements do not exist in isolation. Careful consideration of governance requirements feeds into other important areas such as continuous quality improvement, demonstrating how reviewing and improving compliance in one area can lead to higher levels of compliance in many others. For example, low compliance with the safe and effective clinical care requirement could be linked back to an ineffective clinical governance framework that does not establish effective procedures for the delivery, review and improvement of clinical care. 

The Commission’s provider governance reforms from December 2023 are designed to improve governance in aged care leading to greater levels of compliance with the Standard.

Food and nutrition in focus – Standard 3

The Commission’s Report also called out food and nutrition as a key area of continuing focus, in particular highlighting that high quality food, nutrition and dining can meaningfully improve older people’s quality of life.  

Many of the complaints made to the Commission relate to the service of food and nutrition. In particular, residents of aged care facilities commonly raise concerns about the quality and variety of the food they receive, query whether their food meets their nutrition and hydration needs, or question the availability of food to suit specific dietary needs, including for medical reasons and religious or cultural requirements.  

The impact of food and nutrition is so key to high quality care in aged care that it will be addressed with its own Standard in the forthcoming Strengthened Aged Care Quality Standards. We’ve recently updated our food and nutrition resources to reflect changed requirements in the the proposed Strengthened Aged Care Quality Standards, as well as best practice.  

Improvements in other areas with low compliance can in turn work to aid food and nutrition services. For example, improving planning systems that partner with older people to fulfil Standard 2(3)(c) could include co-design or feedback mechanisms to help older people have greater input into menu and mealtime planning. 

Monitor your compliance with SPP!

It’s important for providers to regularly review their compliance with all eight of the Aged Care Quality Standards. Even if your organisation was compliant at its last audit, regular review of processes can ensure that day to day operations remain consistent with Quality Standards requirements.  It’s also a very important part of the continuous improvement process.

We have a full package of modules in SPP to help providers with their Quality Standards compliance, as well as policy and process reviews.  If you have a detailed grasp of all requirements, you might choose to use our Self-Assessment Tool module to prepare for audit.  Or you might choose our more detailed Educative module to take your team through each itemised requirement of the Quality Standards.  That module presents a series of questions for each requirement, drawn from the Commission’s examples of actions and evidence.  We also have a range of Best Practice modules that focus on other key areas including Clinical Governance, Governance Reforms and Spiritual Care.  All of our modules have integrated links to recommended SPP resources to help you put in place the right policies and procedures. And all of them allow you to generate gap analysis reports and improvement plans.

You can also search our Reading Room for other resources to help improve their processes, either by searching by topic or by standard. For example, searching for ‘planning’ brings up 44 resources that can assist with planning in our resource library, while searching for ‘ACQS2’ brings up all 34 resources that we’ve linked to Standard 2 of the Aged Care Quality Standards.  

Have you reviewed your Quality Standards compliance recently?

Explore how SPP can work for your organisation’s ACQS compliance with a free trial.

Whistleblower Protection in the New Aged Care Act: do you have a Whistleblower policy?

In December 2023 the Department of Health and Aged Care released the exposure draft of the Bill for the new Aged Care Act, which is expected to be finalised in 2025.

The new Act will implement fundamental changes to the current Aged Care Act 1997 and the Aged Care Quality and Safety Commission Act 2018.

One of these changes includes new whistleblower protection requirements for aged care providers. Unlike the Aged Care Act, the new legislation will include specific provisions on Whistleblower Protection under the Information Management Chapter – including a requirement that all registered providers maintain a Whistleblower policy.

We’ve provided below an overview of the key Whistleblower Protection requirements under this legislation to help Aged Care providers prepare for their new obligations. 

What is Whistleblowing?

Whistleblowing is the intentional disclosure of information about wrongdoing or misconduct in an organisation, to the organisation itself, regulatory bodies, law enforcement or the media. Misconduct refers to illegal, improper or unethical conduct which is in breach of legislation, regulation or is generally fraudulent. 

A Whistleblower Protection program protects workers who wish to speak up about wrongdoings or misconduct.

What Qualifies as a Whistleblower Disclosure?

A disclosure qualifies for protection when the individual has reasonable grounds to believe their disclosure indicates an entity has contravened with the law. Under the proposed new Act, this disclosure can be made orally or in writing by an individual associated with the organisation to any of the following: 

  • A member of staff of the Aged Care Quality and Safety Commission (ACQSC);
  • The Secretary (or any other official) of the Department of Health and Aged Care;
  • The Australian Prudential Regulatory Authority (APRA);
  • The Australian Securities and Investment Commission (ASIC);
  • A police officer;
  • An officer, senior manager or auditor of the organisation; or
  • A person that the organisation has authorised to receive a disclosure (this can include a person external to the organisation).

What Protections does a Whistleblower have?

  • The individual is not subject to any civil, criminal or administrative liability for making their disclosure;
  • No contract or remedy may be enforced and no contractual or other right can be exercised against the individual on the basis of their disclosure; and
  • A contract that the individual is a party to cannot be terminated on the basis that their disclosure constitutes a breach of that contract.

So what does this mean for Aged Care Providers?

It is the aged care provider’s responsibility to implement a robust Whistleblower Protection policy for their organisation. This should include:

  • Nominating a qualified/ experienced Whistleblower Protection Officer;
  • Informing their staff of their rights to make protected whistleblower disclosures;
  • Ensuring aged care workers who make a disclosure are not victimised, and that their identity is kept confidential; and
  • Providing support and positive action for whistleblowers (for example, reallocation or a leave of absence while the matter is under investigation).

Most of these requirements are already mandatory under the Corporations Act 2001, while some details are also covered under Division 54 – Quality Care of the Aged Care Act 1997. Therefore, providers should already have some form of Whistleblower Protection policy in place. However, it is important to ensure these policies meet the more in depth requirements of the new Aged Care Act.

How SPP Can Help Your Organisation

To assist providers in preparing for these Whistleblower Protection requirements in the new Aged Care Act, we have these Whistleblower Protection resources:

  • Policy: Whistleblower Protection for public companies;
  • Policy: Whistleblower Protection for small organisations; and
  • Information Sheet: Whistleblower Protection.

All of the above resources can be found in our Reading Room by searching the keyword “whistleblower”.

Want to get a head start on Whistleblower compliance?

Sign up to SPP to access our Whistleblower resources!