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”.

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Evidence-based Care in Aged Care 

The recent publication of a research study by the Australian Institute of Health Innovation highlighted some major areas of concern in the aged care sector. The study focused on the level of adherence to evidence-based care in aged care across 14 different care areas.

What is evidence-based care?

Evidence-based care (or evidence-based practice) involves integrating up-to-date, best practice research with clinical knowledge and experience, and the preferences of the older person. As research and knowledge about a specific clinical care area evolves, an organisation should be reviewing their own processes to ensure that they’re still delivering care that best addresses the needs of older people. Organisations should also ensure that they have effective processes to integrate new or revised evidence into the way they deliver services.

Some factors that may contribute to a person not receiving evidence-based care include: 

  • When an organisation doesn’t regularly check for the latest developments in clinical care areas; 
  • Using outdated, not well supported, or contraindicated evidence as a basis for care;  
  • Failing to adapt care practices to the needs of each older person based on their preferences; and  
  • Failing to implement practices that are based on the latest available evidence. 

Evidence-based care in standards

The requirement to deliver evidence-based care is included in both the National Safety and Quality Health Service Standards (NSQHS) and the strengthened Aged Care Quality Standards (ACQS). Findings of the Aged Care Royal Commission recommended that:

The aged care system should adopt evidence-based and continuous improvement strategies to allow for transparent measurement and reporting of the quality of care being delivered to older people.

Evidence-based (or “evidence-informed”) practice is also a quality indicator of a number of the NDIS Practice Standards, such as those for: 

  • Quality Management; 
  • Responsive Support Provision; and 
  • Behaviour Support.

The Findings of the Research Study

The findings demonstrate that, while some areas of care have relatively high levels of adherence to an evidence-based approach to care, there are also areas that are shockingly low.

On average, the adherence rate across all indicators studied was just over half (53.2%), with a high of 81.3% for continence care, and a low of 12.2% for mental health/depression related care.

Data from Australian Institute of Health Innovation (2024)

Some of these findings match recent results of the Residential Aged Care Quality Indicators from July-September 2023.

Some improvement opportunities

One area of concern is the low adherence to evidence-based practices in medication management, given the high prevalence of polypharmacy in aged care residents, with over a third of aged care residents prescribed nine or more medications.

Another area for improvement is in falls management, where the current ‘best practice’ guidelines date back to 2009. Despite a relatively higher adherence rate to evidence-based care, the trend in falls has remained steady over the past few years, with nearly a third of aged care residents experiencing a fall each quarter during that period. The steady trend reflects the need for continued work to improve knowledge and understanding of clinical care areas in order to aid improvement. New research has informed draft Updated Fall Prevention Guidelines for Residential Aged Care Services, which are currently in a consultation phase. Looking forward,  hopefully the updated guidelines will drive an improvement in fall prevention when they are released, and provide a useful resource for organisations to review their falls management processes and procedures.

A statistically significant area in the recent Quality Indicators that supports the importance of evidence-based care is in continence care. Of the aged care residents who were assessed, 78% were recorded with incontinence, however, only 4% of residents were recorded as having incontinence-associated dermatitis. This indicates that the high level of adherence to evidence-based care in this area is resulting in better outcomes for older people, drastically reducing their likelihood of experiencing incontinence-related issues.

Where to for providers?

This is an opportunity for providers to reflect on their own approach to evidence-based care and practices, especially in the areas of low adherence identified in the research study. In addition, Outcome 5.5 (Clinical Safety) of the Strengthened Aged Care Quality Standards goes into greater detail about many of these areas of care. More specific requirements surrounding specific clinical care areas should act as a tool to guide organisations in providing the level of care older people require.

The Australian Commission on Safety and Quality in Healthcare has some guidance for supporting evidence-based practice, while the NDIS Quality and Safeguards Commission has released their Evidence-Informed Practice Guide, which is a helpful resource to help you consider improvements to processes and procedures.  

BNG and improving care

For further assistance, we have up-to-date policies for many of the areas of care evaluated in the research study, including: 

  • Policy: Promoting Emotional Wellbeing in Aged Care 
  • Policy: Oral Health 
  • Policy: Nutrition, Meals and Hydration
  • Policy: Continence Management
  • Policy: Falls Prevention
  • Policy: Pain Management 
  • Policy: Pressure Injuries
  • Policy: Clinical Deterioration 
  • Policy: End of Life Care and Palliative Care 

In addition, we have information sheets for some topics that provide more in-depth information in areas such as: 

  • Emotional Wellbeing in Aged Care 
  • Nutrition, Meals and Hydration 

Need a refresh on clinical care areas?

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The 10 most common complaints in residential Aged Care

The Aged Care Quality and Safety Commission recently released their first annual report regarding the common complaints received about aged care services. Complaints and feedback play a central role in the quality improvement process, as they can highlight issues of concern that care recipients may have.  Understanding the problem areas of other providers can help to inform your own quality improvement.

In total there were 9,198 complaints submitted to the Commission from July 2022 to June 2023. The Commission identified 10 main complaint categories in residential aged care. These categories provide some insight into the most common issues faced by service users, and will help providers to identify the processes which they could review as part of their continuous improvement system.

As we go through these main complaint categories, we will note resources that we’ve developed which will help providers ensure that they are working to best practice in these areas. If you already have policies and procedures to address these processes, it might still be helpful to review them and compare them with ours.

Common complaint categories for residential aged care:

  • Medication administration and management
    Medication management accounted for 5.5% of complaints received by the Commission. Concerns included issues such as medications being delivered late, identification of patients and medicines, and medications not being started.
    SPP resources
    • Policy: Medication Management
  • Personal and oral hygiene
    Personal care was identified as a problem area for residential aged care providers, with 5.3% of complaints. Personal care includes things such as showering, bathing, and oral hygiene.
    SPP resources
    • Policy: Showering and Bathing
    • Policy: Oral Health (Aged Care)
  • Personnel number/proficiency
    Accounting for 4.8% of complaints about residential aged care, personnel play an essential role in the delivery of safe and quality services. Providers should focus on human resources issues such as recruitment, training, retention, and conditions.
    SPP resources
    • Policy: Employment Conditions
    • Policy: Staff Recruitment
    • Policy: Key Personnel
    • + many more human resources
  • Consultation and communication with family/representatives
    Lack of communication with family and representatives made up 4.4% of residential aged care complaints in the last year. Engagement with family and representatives is important in ensuring that service users are receiving adequate care and services.
    SPP resources
    • Policy: Partnering with Consumers
    • Template: Consumer Advisory Body Terms of Reference
  • Falls prevention
    While falls prevention and post fall management made up only a small portion of the complaints made to the Commission, these areas present a serious risk for providers.
    SPP resources
    • Policy: Falls Prevention (Aged Care)
    • Policy: Showering and Bathing
  • Food and catering
    Quality and variety of food and catering in residential aged care have received increased focus from the Commission recently. And the new Standard 6 (Food and Nutrition) in the Strengthened Quality Standards, currently being piloted, is dedicated to this area. Providers should implement processes to ensure that meals, drinks and snacks are co-designed, nutritious, and varied.
    SPP resources
    • Policy: Nutrition, Meals and Hydration (Aged Care)
    • Template: Mealtime Management Plan
  • Client assessment and service implementation
    Complaints pointed to service implementation and client assessment as areas which providers should review. Client assessments should not only occur at the beginning of service delivery, but should be a regular and ongoing process.
    SPP resources
    • Policy: Client Assessment and Review
    • Template: Client Risk Assessment
  • Consultation and communication
    Communication was another area identified in the Commission’s report as a problem area. With increased focus now on co-design, supported decision-making and consumer advisory bodies, providers should be implementing best practice communication processes.
    SPP resources
    • Policy: Supported Decision-Making and Dignity of Risk
    • Template: Consumer Advisory Body Terms of Reference
  • Physical environment
    Lack of cleanliness in the physical environment was a common complaint received by the Commission from residential aged care service users. Cleanliness is important in upholding the dignity of service users, and infection prevention and control.
    SPP resources:
    • Policy: Hospitality Services
  • Constipation and continence management
    Constipation and continence management accounted for 2.8% of residential aged care related complaints. Though only a small number of complaints were made about these issues, proper management of these areas is essential in providing quality and safe care to service users.
    SPP resources:
    • Policy: Continence Management (Aged Care)

Take this opportunity to review your policies and procedures

The Commission’s new report is a great prompt for providers to consider the identified areas of common complaint as part of their continuous improvement activities.  Ask yourself the following questions regarding each area, to help you determine whether your current procedures could be improved:

  • What complaints and other feedback have we received in each of these areas?
  • What is working well?
  • Are our procedures consistently followed by all workers?
  • Are there improvements we could make?
  • Do we need to update our policies as a result?
  • If so, have we clearly communicated our revised procedures to all workers?

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Preparing for new Aged Care Provider Governance requirements

On December 1, 2023, further changes to the Aged Care Act regarding provider governance will come into effect. The changes aim to strengthen the governance and leadership of aged care providers, while increasing the levels of accountability and transparency of aged care governing bodies. The culture and values of a provider are set at the top levels of the organisation, meaning that an effective and strong governance system is integral to the success of the organisation in practice.  

 Broadly speaking, the new requirements align with: 

  • Standards 6, 7, & 8 of the Aged Care Quality Standards; and, for those looking ahead,  
  • Standards 2 & 5 of the Strengthened Aged Care Quality Standards Pilot Draft.

Who has to comply?

Approved providers of residential, home and flexible aged care services must comply with the provider governance requirements, including providers involved in short-term, multi-purpose and transition care. Providers who became approved on or after 1 December 2022 will already be subject to these requirements, and any provider approved prior to this date must ensure compliance from 1 December 2023 

Providers operating under grant agreements such as the Commonwealth Home Support Programme (CHSP) or National Aboriginal and Torres Strait Islander Flexible Aged Care Program (NATSIFACP) are not required to comply with the provider governance changes. However, they should consider whether aspects of these requirements could be implemented in their organisation as best practice governance.  

What are some of the key requirements?

Who’s on the governing body?

There are new requirements about the skills and qualifications of governing body members, designed to ensure that governing bodies have a strong mix of experience and expertise to drive the right culture and governance systems across the whole organisation. The key requirements are: 

  • The right mix of skills, experience and expertise: Providers should appoint board members who can challenge and analyse how the organisation operates, hold management to account, and who have skills and experience that are relevant to the services their organisation provides.  
  • Experience in clinical care: At least one member of the governing body must now have experience in providing clinical care, in order to provide insights and perspectives of their experience. The input they provide will be important guidance in making decisions about the clinical care operations of the organisation. The type of clinical experience required is not specified, as it will differ amongst providers, but it should be relevant to the care and services provided.  For example, if a large proportion of the clinical care provided to older people involves physiotherapy, it would be good practice to have a person with physiotherapy experience as a Board member.
  • Majority of independent non-executives: A majority of the governing body members must now be independent non-executive members. This change is designed to reduce conflicts of interest for those serving on boards, and ensure that decisions are made objectively and in the best interests of care recipients. There is no prescribed definition of “independent non-executive members”, so whether a person is independent or not will be a matter for each organisation to determine. Organisations should consider whether each candidate for Board membership is able to perform their duties independently, without the influence or conflict of any outside or personal interests. Some examples of people who would not be independent would include:
    • Paid staff members of the organisation; and
    • Owners of the organisation, including shareholders and employees of parent or holding companies.

Some providers don’t need to meet the governing body requirements

If a provider is one of the following, they are exempt from these requirements: 

  • Approved providers that are a state, territory or local government authority; 
  • Providers who have fewer than 5 members in their governing body and provide care to fewer than 40 care recipients; and 
  • Approved providers that are Aboriginal Community Controlled Organisations (ACCOs). 

If these circumstances change, the organisation will be required to comply, for example if they begin to provide services to 40 or more care recipients.  

Additionally, providers who cannot meet the governing body requirements may apply to the Commission for a determination, but this should only be attempted after exhausting all possible avenues for meeting the requirements, and is not designed to be a permanent exemption from compliance. In particular, providers in rural or remote areas might face greater difficulties in finding suitable members to serve on their governing bodies, although this is not an automatic justification for exemption. Organisations should use alternative attempts to facilitate compliance, such as online meeting software or networking with other providers in similar situations to find candidates, before making an application.  

Advisory body requirements

The new changes set out various requirements for advisory bodies, specifically a quality care advisory body and a consumer advisory body. Advisory bodies are groups that assist governing bodies by providing advice and information about specific issues. They are separate from the governing body and don’t have the responsibilities of a governing body. 

The quality care advisory body

This advisory body is designed to support the governing body with their decision-making and continuous improvement, by identifying and reporting on any issues of concern relating to the quality of the care provided by the organisation.  

The quality care advisory body must provide a written report to the governing body at least every 6 months, and can also provide feedback at any other time.  The report will be based on the quality care advisory body’s review of a range of performance indicators, including: 

  • Feedback and complaints about the quality of care; 
  • Any regulatory action taken, or performance reports provided, by the Commission; 
  • The organisation’s progress against its continuous improvement plan; 
  • Information about staffing arrangements; 
  • Any reportable incidents; and 
  • Feedback and details about the quality of food provided (for residential aged care providers). 

The governing body must provide a written response to feedback and reports from the quality care advisory body, in which it responds to the issues identified and sets our proposed actions to address those issues. 

Organisations don’t need to create a new body for this purpose if an existing body or group meets all the requirements and performs the same functions. Membership of the quality care advisory body must include:  

  • a member of the organisation’s key personnel (ideally not someone who is on the governing body) who has experience providing aged care;  
  • a staff member who is directly involved in providing aged care or clinical care services; and  
  • a member representing the interests of older people/care recipients (for example, a care recipient, family member, carer or representative).  

It is recommended that the chairperson of the quality care advisory body is independent, and not an executive of the organisation. 

The consumer advisory body

At least once every 12 months, organisations must make a written offer to older people to establish a consumer advisory body, and invite them to join it (or to join an existing consumer advisory body, if one or more already exist).  It is not mandatory to actually have a consumer advisory body, however it is mandatory to make the annual offer in writing to establish one. 

This body provides the governing body feedback, concerns and suggestions from the consumer perspective, highlighting areas of focus that the governing body may otherwise miss, and helping to incorporate the views and wishes of consumers into how services should be designed and improved . Issues, concerns and feedback a consumer advisory body provides must be considered by the governing body in their decision-making and continuous improvement processes, and a written report must be provided to the consumer advisory body explaining how their feedback has been considered. 

Additional provider governance changes

  • Governing bodies need to make sure their staff have appropriate skills, qualifications and experience to fulfil their roles when delivering aged care services, including providing staff withy professional and skill development opportunities; and  
  • Organisations that are a wholly-owned subsidiary of another body corporate (known as a holding company) which is not an approved provider must ensure their constitution requires company directors to act in the best interest of older people rather than prioritising the interests of their holding company. 

Commission resources

The Aged Care Quality and Safety Commission has created several fact sheets on provider governance changes: 

They have also published responses to common questions about the new governing body requirements, which could be a good place to start if you have further questions about how the governing body requirements and determination process work.  

BNG resources

We’ve created 5 new templates and revised some of our existing policy documents to help providers with their new governance requirements: 

  • Template: Consumer Advisory Body Terms of Reference 
  • Template: Invitation to join Consumer Advisory Body 
  • Template: Written response to Consumer Advisory Body Report 
  • Template: Quality Care Advisory Body Terms of Reference 
  • Template: Written response to Quality Care Report 
  • Policy: Provider Governance (Aged Care) 

These new resources join our existing package of provider governance resources that we released in late 2022, which includes: 

  • Policy: Key Personnel 
  • Template: Key Personnel Suitability Checklist 
  • Template: Key Personnel Declaration and Undertaking 
  • Template: Governing Body Requirements Checklist 

We also have a whole range of aged care self-assessment modules in SPP including for: 

  • The current Aged Care Quality Standards 
  • The Strengthened Aged Care Quality Standards Pilot Draft 
  • Clinical Governance 
  • The Aged Care Prudential Standards 
  • The Aged Care Code of Conduct 
  • Provider Governance Reforms 

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Changes to nutrition in aged care are coming… are you ready?

The Royal Commission’s Recommendation

One of the major changes coming to Aged Care is the strengthening of the Aged Care Quality Standards based on the findings and recommendations of the Aged Care Royal Commission. A key area of focus of the Royal Commission was the nutrition, hydration and dining experience of residents in aged care.

The Royal Commission recommended:

imposing appropriate requirements to meet resident nutritional needs and ensure meals are desirable to eat, having regard to a person’s preferences and religious and cultural considerations. 

New requirements

Following the review of the Quality Standards, the Pilot Draft of the Revised Quality Standards now contains Standard 6: Food and Nutrition. This is a completely new standard, which will apply only to residential aged care services.

Standard 6’s expectation statement for older people is: 

I receive plenty of food and drinks that I enjoy. Food and drinks are nutritious, appetising and safe, and meet my needs and preferences. The dining experience is enjoyable, includes variety and supports a sense of belonging. 

Standard 6 notes that access to nutritionally adequate food is a fundamental human right, and draws attention to the fact that food, drink and the dining experience can greatly impact a person’s wellbeing. The Standard sets out a number of new concepts for aged care providers, including new or enhanced actions and requirements to: 

  • Partner with older people on how to create an enjoyable food drinks and dining experience;  
  • Monitor and continuously improve food services in accordance with the feedback of older people;  
  • Regularly assess the nutritional and dining needs of each older person;  
  • Review menus in partnership with both older people and health professionals;  
  • Promote choice about what, when, where and how older people eat and drink;  
  • Offer and enable access to snacks and drinks at all times;  
  • Ensure sufficient workers are available to assist in the dining experience;  
  • Ensure that the dining experience promotes belonging and enjoyment; and 
  • Offer older people the opportunity to share food and drinks with their visitors.  

New resources from the Commission

The Commission has recently released some new resources to help providers better understand the importance of choice in food and drink in aged care, as well as the dining experienceThe full list of the Commission’s resources includes information for providers, staff and consumers, and can be found here. Some of the key new resources are:

How SPP can help

To assist providers get up to speed with the new food and nutrition requirements that will be in Standard 6, we’ve recently summarised all necessary information into a helpful information sheet. We have also incorporated the new and enhanced actions and requirements of Standard 6 into our comprehensive policy document.  

  • Info: Nutrition, Meals and Hydration 
  • Policy: Nutrition, Meals and Hydration (Aged Care) 

Other resources for service providers

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How an effective call bell system can improve service provision 

An effective call bell system is a key part of safe and quality care delivery in facilities providing services to care recipients. It can play an important role in risk mitigation, staff management and ongoing continuous improvement processes, and also helps demonstrate to your care recipients your organisation’s commitment to safe and high quality services.  

Promptly responding to call bell requests from care recipients can aid in risk management and the prevention of issues such as falls or pressure injuries. Long or delayed response times for call bells can be a sign of policy or procedure issues relating to the staff model or communication. Monitoring call bell response times and the reasons for the calls can contribute to identifying opportunities to improve service delivery.

It’s therefore vital for organisations to have processes and procedures in place to provide this assistance for their care recipients.  

1. Staff management

One of the most important aspects of a call bell system is the provider’s ability to respond to requests in a timely way. To achieve this, facilities must manage their staffing and rostering to support their staff’s ability to respond to call bells. Failure to roster enough staff, overburdening staff with too many responsibilities, and a lack of communication around expected responsibilities, priorities and processes are all common explanations for high call bell response times. 

2. Standards compliance

While you won’t find call bells specifically mentioned in standards requirements, there’s a lot of indicators that can be supported by good call bell response practices. For example, in a number of Provider Performance Reports, the Aged Care Quality and Safety Commission has referred to call bell response times and reporting as relevant to its assessment of compliance by providers with: 

  • Standard 3(3)(b)Effective management of high-impact or high-prevalence risks associated with the care of each consumer; 
  • Standard 7(3)(a)The workforce is planned to enable, and the number and mix of members of the workforce deployed enables, the delivery and management of safe and quality care and services; and 
  • Standard 8(3)(d) – Effective risk management systems and practices 

As another example, for care facilities following NSQHS, call bell system management and reporting is relevant in relation to the Clinical Governance Standard and the Comprehensive Care Standard 

3. Quality improvement

Reviewing call bell response records can form an important part of an organisation’s continuous quality improvement processes. Accurate records of the reasons for each call bell use, as well as response times, are useful for verifying care recipient and staff feedback and/or complaints and highlighting where improvements can be made in service procedures. Commonly listed reasons for response times outside the target window indicate opportunities for organisations to review current processes and how they impact safe and quality service delivery. 

How SPP can help

We’ve developed a new policy template for providers with call bell systems to optimise their call bell procedures. The template will help providers set response time KPIs, clarify staff responsibilities, and put in place regular reporting and analysis.  

In addition, our SPP self-assessment platform allows providers to link their call bell records as evidence against relevant Standards. 

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What’s New in Medication Management?

A growing number of Australians are remaining at home as they age rather than living in residential aged care facilities.  Many are moving into facilities at an older age, or when they develop conditions requiring greater care. In addition, the rise of polypharmacy (the use of multiple medicines by one person) and chronic disease raises increased challenges for medication management. In 2019, the Council of Australian Governments Health Council announced the Quality Use of Medicines and Medicines Safety as Australia’s 10th National Health Priority, in recognition of the increased risks of harm relating to the use of medicines.

The Department of Health and Aged Care has recently updated its Guiding Principles in response to this National Health Priority and the societal changes relating to medication management, with three Quality Use of Medicines (QUM) resources. These guidelines are not prescriptive, but demonstrate best practice for providers when managing consumer medications. They ensure consistency of care across the spectrum of care settings, with broadly standardised expectations of healthcare providers in medication management.  

Each set of guiding principles includes some overarching general principles, which inform the implementation of the specific remaining principles. They are designed to be used in conjunction with relevant legislative, profession-specific and accreditation requirements, and affirm a patient-centred, whole-of-organisation approach to care, as well as strong clinical governance. 

All three QUM documents are now consistent with other standards, such as the Aged Care Quality Standards, as well as aligning with each other for a cohesive approach to medication management.  

For example, Guiding Principle 1 (Person-centred care) is common to both the RACF and Community principles, and connects to Guiding Principle 8 (Sharing decision making and information about medicines with the individual receiving care) of Continuity in Medication Management. The diagram to the left shows where principles in the three documents overlap. For more information about the areas of commonality and differences between the three guiding principles, take a look at this guide from the Department of Health. 

1. Guiding Principles for Medication Management in Residential Aged Care Facilities (RACFs)

These Guiding Principles build on the 2012 RACF Medication Management principles, with the addition of two leading principles, Person-centred care and Communicating about medicines. Both align the Guiding Principles with Standard 1 (Consumer dignity and choice) of the Aged Care Quality Standards, and aim to actively engage consumers with their care. Other existing principles have been reorganised, combined, and renamed for greater consistency with the broader network of safety and quality standards. 

2. Guiding Principles for Medication Management in the Community

The Community Medication Management guiding principles have evolved from their 2006 predecessor and, similar to the RACF principles, have new principles relating to person-centred care and communication, to promote a person-centred partnership and systems-based approach when support is being provided to people living at home. The previous guiding principles have also been adjusted to match the wording of the RACF guiding principles, where they share common best practice. 

3. Guiding Principles to Achieve Continuity in Medication Management

Finally, the 2005 Continuity in Medication Management guiding principles have been updated to reflect current priorities and best practices relating to consistent, safe, and quality care across healthcare providers and at transition of care, including the addition of a Safety and quality systems principle.

BNG and Medication Management

We’ve updated our Medication Management policy document to reflect some of the key changes in the new Guiding Principles documents, available now in the Reading Room. In addition, we also have a range of templates that can be used as a starting point for your organisation to develop a comprehensive approach to medication management that:  

  • best suits the needs of your clients and the services you provide, and  
  • ensures your service delivery is in line with current best practice.  

Looking for more information?

The Australian Government Department of Health and Aged Care has created fact sheets for each new set of Guiding Principles, explaining each principle and some key tasks for achieving them: 

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Looking back on 2022

The past year has been a time of significant change and challenge for the Australian community and health service sector. In addition to dealing with the ongoing impact of the COVID-19 pandemic, many areas were also affected by severe flooding. Meanwhile, the sector has also had to navigate a number of major regulatory changes. We acknowledge the resilience and dedication of our community and health service providers, to whom we are committed to providing services and resources to support them in their efforts. In this blog post, we will highlight some of the key areas we have focused on and look ahead to what’s to come in 2023.

Aged care

2022 has been a major year for aged care reform in Australia with key legislation introduced in July.  The Code of Conduct for Aged Care came into effect on December 1, 2022, and we have developed a self-assessment to help providers ensure they are meeting the requirements of this new code.

A series of governance requirements also commenced on December 1, and we have developed a suite of resources including policy templates and checklists to help providers get on top of these.

In addition, the Serious Incident Response Scheme (SIRS) was extended to home care and flexible care delivered in a home or community setting on December 1. In response, we published a new SIRS policy for home care providers. Looking to 2023, we will be developing new resources and assessment modules to help providers prepare for the revised Aged Care Quality Standards, which are currently in consultation draft form.

Disability services

In the disability sector, we developed guidance and a number of resources for the new NDIS emergency and disaster management standard. The emergency and disaster management standard has ongoing relevance, and our collection of resources, including an organisational emergency and disaster plan, and participant-specific risk assessment template, will help providers to implement the standard.

We’ve also developed resources to help providers publish policies in Easy English, which is an important tool for helping participants make informed choices and understand their rights. And we have provided information on the use of surveillance technology in this sector.

Child safe

In the area of child safety, we have developed self-assessments and provided updates on the implementation of child safe standards in each jurisdiction.

We have also looked at the National Quality Framework and discussed some upcoming changes to this framework, and we released a detailed self-assessment for the National Quality Standard.


We have released new self-assessments for the ISO standards, including ISO 45001: 2018 Occupational Health and Safety Management Systems, which can help providers to implement a best practice approach to occupational health and safety.

In 2023, we plan to extend our ISO offering, by releasing assessment modules for ISO 14001: 2015 – Environmental Management Systems and ISO 31000: 2018 – Risk Management.

Additionally, we have developed several new Towards Best Practice modules on topics such as Information Management and Privacy, to provide foundational guidance on good governance.

Until next year!

As the holiday season approaches, we would like to extend our best wishes to the NGO community. We are grateful to have had the opportunity to provide services and resources to support the important work you do. We are committed to delivering the best possible support to help you meet the various standards and regulations in your field, and we have a number of new self-assessments and resources in the works for the new year.

We hope you have a wonderful Christmas and holiday period, and we look forward to continuing to work with you in the new year. Happy holidays!

Need help with standards and compliance?

Code of Conduct for Aged Care comes into effect today!

We have previously written about the introduction of a Code of Conduct for Aged Care. The Code has now been finalised and applies to approved providers, aged care workers, and governing persons from today, the 1st December 2022.

The Aged Care Quality and Safety Commission has published a Code of Conduct for Aged – Guidance for approved providers document, and we encourage providers to review this guidance, where they can find useful examples of what the Code looks like in practice.  Our self-assessment modules for the Code, available on SPP are a great resource for organisations looking to ensure their readiness for the Code.

Also coming into force today are a number of responsibilities relating to provider governance, including:

  • Notifying the Quality and Safety Commission of material changes to provider suitability
  • Consideration of suitability of all key personnel
  • Notifying the Quality and Safety Commission of changes regarding key personnel
  • Ensuring appropriate staff qualifications, skills and experience
  • Reporting on providers’ operations and statement of compliance

We have developed a package of resources to assist aged care providers with these new governance requirements, including the following:

  • Self-assessment module for Provider Governance responsibilities
  • Policy: Provider Governance (Aged Care)
  • Policy: Key Personnel
  • Template: Key Personnel Suitability Checklist
  • Template: Key Personnel Declaration and Undertaking
  • Template: Governing Body Requirements Checklist

You can find these new resources in the Reading Room of your SPP or ACCPA Quality Portal account, by searching for “aged care governance”.

Looking for assistance managing your aged care obligations?