Catholic Health Australia – Submission on Stage 4a Release of Rules

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 the Stage 4a Rules relating to place allocation and other provider obligations. We look forward to working with the Department during the consultation on the draft Rules to ensure the new Aged Care Act and supporting Rules 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 draft Rules relating to provider obligations and funding for aged care services. CHA appreciates the work undertaken by the Department to address the mechanisms relating to the starting, continuing and ceasing of funded aged care services in this release of the Rules. This submission provides specific considerations for implementation of the Rules to ensure transparency and accountability in all aspects of service delivery for older Australians.

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

1. Starting, continuing and ceasing of service provision: CHA welcomes the drafted provisions relating to security of tenure arrangements for residential care, and similar provisions for all other funded aged care services. Recommendations outlined in this section detail specific implementation considerations to improve the applicability of these provisions for older Australians, and to enable providers to better understand how to best meet the care needs of older Australians within the remit of these provisions on service delivery.
2. Cooperation with other persons: CHA notes that the draft Rules prescribe the need for providers to comply with requests from Pricing Authority to facilitate access to their premises, responsible persons, and aged care workers. Specific recommendations have been set out in this section to support the implementation of these provisions in a fair and appropriate manner.
3. Accommodation payments: CHA is supportive of the provisions relating to the management of accommodation payments, as prescribed in the draft Rules. Specific considerations have been detailed in this section to mitigate the risk of potential misinterpretation of concepts that are not yet defined in the draft Rules nor within the associated components of the new Act.