Catholic Health Australia – Rules Stage 3 Release Submission March

Executive summary

Catholic Health Australia (CHA) is Australia’s largest non-government grouping of health, community, and aged care services accounting for approximately 12 per cent of aged care facilities across Australia, in addition to around 20 per cent of care provision in the home. Catholic aged care providers have a vital interest in working with the Australian Government to ensure the sustainable provision of aged care and support services for older Australians meet community expectations of safe and quality of care.

CHA appreciates the opportunity to provide input into Stage 3 of the Aged Care Act (2024) Rules. We look forward to working with the Department during the consultation process to ensure the Rules on provider obligations achieves its intended outcomes. Our goal is to ensure it fully supports a high-quality and safe aged care system for all Australians irrespective of their wealth or geography.

Overall CHA is supportive of the intent and purpose of the Rules in setting out the reporting obligations for aged care providers. CHA appreciates the work undertaken by the Department of Health and Aged Care to address provider obligations, the Strengthened Quality Standards; and workforce requirements. We have made suggestions in response to the Department’s consultation questions as to how CHA and its members would like to be communicated with.

However, CHA and its members are concerned about the additional administrative burdens imposed on the sector due to demanding reporting requirements and, at times, duplicative processes, and unintended consequences of possible attrition for the aged care and volunteer workforce in attempting to meet these requirements. This submission details options to support a cohesive implementation of these reporting requirements while avoiding unintended consequences to the sector.

Key observations and issues related to this release of the Rules articulated in our submission include:

1. Reporting obligations: Although the Rules mostly reflect existing reporting requirements, some new obligations seem duplicative and add administrative burden. Given the implementation timeframes, CHA and its members are concerned about the feasibility of meeting all obligations by 1 July 2025.
2. Aged care workforce: Significant change management is needed to ensure providers comply with the Rules by 1 July 2025. All aged care workforce members must be trained and upskilled to understand their reporting roles, posing a risk to care provision due to the heavy administrative burden.