Catholic Health Australia Submission: National Safety and Quality Health Service Standards (third edition)

Executive summary

The third edition consolidates eight standards into three and shifts the emphasis from specifying clinical processes to describing the systems and culture that produce high-quality care. CHA supports that direction. It reflects where the sector has moved, and it reflects much of what CHA put to the Commission in October 2025.

The draft delivers on several of those earlier recommendations. High-quality care is defined as a set of interconnected domains rather than as the absence of harm, and that definition carries through all three standards. Consumer partnership is distributed across the Standards rather than confined to one. Environmental sustainability and climate resilience are embedded in the requirements rather than published as a parallel module. Each of these was a CHA position and each is a material improvement on the second edition.

The difficulty is the distance between what the draft states and what it can deliver. The consultation asks whether the third edition reduces compliance burden while maintaining safety and quality. That question cannot be answered from the material published. The draft reduces the number of standards, but contains 79 requirements, 286 lettered sub-requirements and 22 further sub-elements beneath those. Without a mapping from the second edition and a regulatory burden analysis, neither CHA nor its members can say whether the assessable load has fallen, risen or stayed the same. The Commission published a regulation impact statement when it made the second edition. The third edition is a larger structural change and warrants the same.

The same gap runs through the assessment model. The draft states that implementation and assessment should be proportionate to the size, scope, complexity, clinical risk profile, service model and digital maturity of the service. That statement appears once, in the introduction, and in none of the 79 requirements. Nothing in the draft says who decides what is proportionate, on what criteria, or what a service can do if it disagrees. Broader, outcome-focused wording assessed by six accrediting agencies under an unchanged scheme is more likely to increase variation between assessors and defensive documentation by services than to reduce burden. Proportionality matters most to the services least able to carry the cost, being small rural hospitals and single-specialty day procedure services, where accreditation consumes a far higher share of total cost and where the accreditation coordinator is often also the clinical educator and the infection prevention lead.

Two omissions require attention on their own terms. The word spiritual does not appear anywhere in the draft, although the Commission’s own end-of-life consensus statement names spiritual need as a guiding principle, and the Strengthened Aged Care Quality Standards require providers to support it. A resident moving from a residential aged care home to a hospital crosses from a regime that names spiritual need to one that does not. Separately, the named clinical harms carried by the second edition, including pressure injuries, falls, nutrition, delirium and venous thromboembolism, are absent from the draft, with no published mapping showing where those obligations have gone. These are among the highest-volume preventable harms in Australian hospitals and among the actions services found hardest to meet.

CHA makes 16 recommendations. They fall into four groups: restore what is missing from the scope of the Standards; publish the evidence base for the burden claim before the 2027 pilot; make proportionality operate inside the Standards rather than sit above them; and sequence the requirements that depend on national infrastructure to the timetable on which that infrastructure will exist.