Assessment Manual
Applications for the
Higher Accommodation Supplement
for services which have undertaken
a Significant Refurbishment
1
1. Contents
1.
Contents........................................................................................................................ 2
1.
Introduction ................................................................................................................... 3
2.
2.
1.1.
Purpose .................................................................................................................. 3
1.2.
Protected Information.............................................................................................. 3
Preliminary application and assessment process .......................................................... 3
2.1.
Receipt of Applications ........................................................................................... 3
2.2.
Completeness Check .............................................................................................. 3
Assessment Process ..................................................................................................... 4
2.1.
Initial Assessment ................................................................................................... 4
2.2.
Seeking further information ..................................................................................... 4
2.3.
Assessment ............................................................................................................ 5
2.3.1
Standard and Pre-approval Applications .......................................................... 5
2.3.2
Confirmation of Completion of a Pre-Approved Significant Refurbishment ..... 12
2.4.
3.
Assessment finalisation ........................................................................................ 13
Definitions ................................................................................................................... 14
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1. Introduction
1.1.
Purpose
This manual has been developed for the use of Department of Social Services (DSS)
officers to support the assessment of applications from approved providers seeking a
determination that their service is significantly refurbished.
The manual should be read in conjunction with the relevant sections of the Aged Care Act
1997 (the Act), the Subsidy Principles 2014 (the Principles), the Higher Accommodation
Supplement application forms and the Guidelines for Applying for the Higher
Accommodation Supplement.
1.2.
Protected Information
Assessors must familiarise themselves with Division 86 of the Aged Care Act 1997, which
relates to the protection of information, including the use and disclosure of protected
information.
Protected information is defined under section 86-1 of the Act as information that:
a. was acquired under or for the purposes of the Act; and
b. either :
i.
is personal information; or
ii.
relates to the affairs of an approved provider; or
iii.
relates to the affairs of an applicant for approval under Part 2.1; or
iv.
relates to the affairs of an applicant for a grant under Chapter 5.
All information provided by approved providers applying for the Higher Accommodation
Supplement must be treated in accordance with the protected information provisions of the
Act.
2. Preliminary application and assessment process
2.1.
Receipt of Applications
Applications may be received via a web based form, email or hard copy. They are entered in
the Higher Accommodation Supplement database. Each application will be allocated a
unique reference number. The statutory timeframes for a determination by the Secretary will
commence from the date of receipt of a valid application by the Department.
2.2.
Completeness Check
Applicants are required to submit their applications to either the Department or Forms
Administration on behalf of the Department.
Upon receipt of an application, an initial check will be conducted by Forms Administration to
confirm the application is complete including confirming the:

applicants are approved providers;

information has been provided on the approved form; and

application contains all the required information in a clear and comprehensible form
(all required fields on the application form have been appropriately completed; a
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supporting statement has been provided, the relevant supporting evidence has been
provided).
Where all requirements to make a valid, complete application have been satisfied, Forms
Administration will forward the application to the Department for assessment.
Where all requirements to make a valid, complete application have not been met, Forms
Administration will contact the applicant and request that they either provide the missing
information or resubmit their application.
2. Assessment Process
2.1.
Initial Assessment
On receipt of a complete application by the Department, the application will be assigned to a
DSS officer for assessment. The first step will be for the assessor to undertake a high level
review to determine if sufficient information has been provided to enable the delegate to
confirm the legislative criteria have been met.
If the assessor is satisfied the application contains sufficient information, they will commence
the assessment process. If an assessor identifies further information is required, the
assessor may seek further information.
2.2.
Seeking further information
The Principles outline the criteria the Secretary, or their delegate, must be satisfied are met
in order to make a determination that a residential aged care service is Significantly
Refurbished. If the initial assessment determines insufficient information has been provided
to enable this determination to be made, a request will be made of the applicant to supply
further information.
Where the need for further information is identified, the assessor will determine the
appropriate form of contact with the applicant. All communication between the assessor and
the applicant is required to be logged in the Higher Accommodation Supplement database. If
the additional information required is minor in nature, the assessor may choose to contact
the applicant by telephone and/or email.
Where the application lacks sufficient information in a number of areas and/or the issue of
concern is complex, a formal request for further information (as provided for under
section 55 of the Principles) will be made by the assessor. The assessor will send the
applicant a letter which clearly outlines the issue(s) requiring clarification and the further
information sought. Every effort must be made to ensure all further information requests are
covered within a single request.
The Principles require the Secretary or their delegate to provide written notification of the
standard approval and pre-approval application outcome within 60 days after receipt of a
valid application, unless the Department has made a request for additional information.
Where a request for further information has been made under section 55 of the Principles,
the period of time starting from the date of request through to and including the date of
receipt by the Department of the additional information is not counted towards the 60 day
period.
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The applicant is required to provide the additional information within 28 days, or earlier if
specified, after receiving the request. The application is taken to be withdrawn if a response
is not provided within the 28 day timeframe.
2.3.
Assessment
Applications deemed to contain sufficient information are assessed against the significant
refurbishment eligibility criteria defined in the Principles.
The approach to assessing each of the application types is set out in the following sections:

2.3.1
Standard and Pre-Approval Applications.

2.3.2
Confirmation of Completion Applications.
2.3.1
i.
Standard and Pre-approval Applications
Refurbishment completion date
Standard approval may only be sought after completion of the refurbishment or where the
refurbishment is sufficiently advanced to qualify based on the work already completed.
Section 52(2)(a) of the Principles require significant refurbishment projects to have been
completed on or after the 20 April 2012 to be eligible for the higher supplement. The
completion date of a refurbishment will be taken to be the later of either the date on which
the refurbished facility was deemed suitable for occupancy by state/territory building
authorities, or the date on which all work involved in the refurbishment was finished.
Where a staged project started before 20 April 2012 and the most recent stage was
completed on or after 20 April 2012, the refurbishment will be taken to have been completed
on or after 20 April 2012. However, for staged projects it must be clear that all work
(completed before and after 20 April 2012) was part of one distinct refurbishment project.
If the refurbishment consisted of:

an extension to the facility only (e.g. building a new accommodation wing), the
completion date is the date on which the occupancy certificate (or equivalent) was
issued for the extension.

alterations, updates, upgrades or other improvements to existing parts of the facility,
the completion date is the date on which all work involved in the refurbishment was
finished.

both an extension and alterations, updates, upgrades or other improvement to
existing parts of the facility, the completion date is the later of either the date on
which the occupancy certificate (or equivalent) was issued or the date on which all
work involved in the refurbishment was finished.
Assessors are to review the completion date provided in the application and the date on the
occupancy certificate (or equivalent) where applicable, to verify this criterion has been
satisfied.
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ii.
Significant difference
The refurbishment is required to include alterations, updates or other improvements that
have resulted in the service being significantly different in form, quality or functionality after
the refurbishment.
The assessor will review the information provided in the application for evidence that the
refurbishment has, or will, result in a significant difference in form, quality, or functionality to
the service. The improvements to the service should be readily discernible and clearly
demonstrate a significant enhancement of amenity and accommodation accessible to and
for use by care recipients.
iii.
Accessible and for the use of care recipients
The assessor will review the information provided in the application to determine if a
significant proportion of the refurbished areas of the service are, or will be, accessible to,
and for the use of the care recipients.
Examples of refurbishment areas which satisfy this criterion include: care recipients’ rooms
(including en-suites), shared toilets/bathrooms; areas available to all care recipients
irrespective of their means; common areas for care recipients; and rehabilitation areas.
While some work to areas that are not accessible to, or for the use of, care recipients is
permitted, in general the costs of refurbishment work to ‘non-accessible, non-usable areas’
should not comprise more than 10 per cent of the minimum monetary spend amount.
However, where the associated costs exceed 10 per cent, assessors will consider the
significance, scope, and expenditure of the overall refurbishment in assessing whether this
criterion has been satisfied.
Examples of areas that are not considered to be accessible to, and for the use of, care
recipients include:

administrative areas;

vehicle garaging areas; and

areas for storing cleaning or maintenance products or equipment for use either
internally or externally.
A refurbishment project which consists solely of maintenance related work will not be
determined to be a significant refurbishment.
Building work, such as, painting, electrical, plumbing, tiling, finishing etc., can be included
within a refurbishment project, where the project plan and documentation demonstrates that
this work is part of the significant refurbishment rather than normal maintenance activity.
Where the assessor is unable to determine if a refurbished area is or is not accessible to or
for the use of care recipients, further information will be sought from the applicant.
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iv.
Significant benefits for eligible care recipients
The assessor will review the information provided in the application to determine if the
refurbishment does, or will, provide significant benefits to eligible care recipients.
Examples of refurbishments that are considered to provide significant benefits to care
recipients include:

improvements to care recipients’ rooms that are available to eligible care recipients;

the availability of care recipients’ rooms within a new accommodation wing to eligible
care recipients;

new or improved common areas that are accessible to eligible care recipients;

new beds for eligible care recipients;

ceiling hoists and other care related equipment for eligible care recipients;

entertainment equipment for use by eligible care recipients.
Note: “Eligible care recipients” is defined in the Definitions section.
The changes would need to be significant in nature, as opposed to minor upgrades to
facilities and/or work that consisted solely of maintenance related activities. The refurbished
areas must also be accessible to, and for the use of eligible care recipients.
The above list is not exhaustive; other types of refurbishment may meet this criterion,
v.
Minimum monetary spend amount
Section 52(2)(h) requires the refurbishment cost in relation to the service to be at least the
minimum monetary spend amount.
The minimum monetary spend amount is worked out by multiplying $25,000 by 40 per cent
of the lower of:
a) the total number of care recipient rooms in the service before the commencement of
the refurbishment; and
b) the total number of care recipient rooms in the service after the completion of the
refurbishment.
The assessor will review the information provided under items 5 and 6 of the application
form to determine the number of care recipient rooms that will be used to calculate the
‘minimum monetary spend amount’ for the service.
For standard applications, the assessor is required to verify the number of care recipient
rooms stated on the application form by reviewing the supporting evidence provided with the
application and the number of current operational (including extra service) places recorded
in the National Approved Provider System (NAPS) database for the service. If the number of
operational places in NAPS differs from the application information, the assessor will seek
clarification from the applicant.
For pre-approval applications, the assessor will verify the number of care recipient rooms
stated on the application form by reviewing the supporting evidence provided with the
application.
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vi.
Available rooms for eligible care recipients
The assessor will determine (using the information provided in the application, in conjunction
with information held by the Department) whether the proportion of care recipient rooms
available to eligible care recipients after completion of the refurbishment is not, or will not, be
lower than the proportion before commencement of the refurbishment. “Available” means
that eligible care recipients would not be ordinarily excluded from accommodation in those
rooms (eg. the room is not an extra-service room).
Care recipient rooms are required to be potentially available to eligible care recipients,
however they may not necessarily be continuously occupied by eligible care recipients. This
recognises that on occasions, a particular care recipient room may be occupied by a care
recipient who is not eligible for Government support with their accommodation costs.
Assessors will consider any current and active allocation of Extra Service places for the
service as part of this process. The total number of places minus the active allocation of
Extra Service places is the number of care recipient rooms that could be expected to be
available to eligible care recipients pre and/or post the refurbishment.
Note: “A care recipient’s room” is defined in the Definitions section.
vii.
Minimum required benefits
Assessors will determine whether at least one of the requirements outlined in
Section 52(2)(f) has been, or will be, met.
That is, the refurbishment:
a) Has or will result in at least 40 per cent of the care recipients being provided with
residential care through the service having a care recipient room that has been
significantly refurbished; or
b) Has or will provide a significant benefit to at least 40 per cent of the care
recipients being provided with residential care through the service; or
c) Has or will consist of an extension to the service involving an increase of at least
25 per cent of the number of care recipient rooms in the service.
The assessor considerations for each of the above criteria are as follows:
a) Has or will result in at least 40 per cent of the care recipients being provided with
residential care through the service having a care recipient room that has been
significantly refurbished.
The 40 per cent requirement applies to the total number of operational places in the service
at the time of application.
The current number of operational places is to be determined by reviewing service details in
the NAPS database.
b) Has or will provide a significant benefit to at least 40 per cent of the care
recipients being provided with residential care through the service.
In cases where the main focus of the service refurbishment is on common areas, the
refurbishment must significantly benefit at least 40 per cent of care recipients being provided
with care in the service.
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Only undertaking a refurbishment of common areas in the facility will not generally satisfy
this criterion, as it is expected that common area refurbishments are supplemented by some
refurbishment of care recipient rooms. However, refurbishments of this type are to be
considered on a case-by-case basis, with consideration given to the extent of improvements
made to the common areas and the resulting benefits to care recipients.
c) has or will consist of an extension to the service involving an increase of at least
25 per cent of the number of care recipient rooms in the service.
To satisfy this criterion an extension to the service must increase care recipient rooms by
25 per cent. This requirement relates to the total number of operational care recipients
rooms in the service, not just the rooms that are occupied at the time of application.
Where a provider undertakes an extension that does not increase the number of care
recipients’ rooms by 25 per cent, the provider may meet the requirements of section 52(2)(f)
if, in combination with the additional care recipients’ rooms in the new wing, the approved
provider makes additional significant improvements to existing care recipients’ rooms or
common areas in the residential care service.
viii.
Refurbishment costs
The refurbishment cost is equivalent to the total cost of the refurbishment project, unless fire
safety improvements have been undertaken as part of the refurbishment.
The refurbishment cost is exclusive of the Goods and Services Tax (GST), it includes all the
reasonable costs that were necessary to complete the refurbishment. Professional and
consultant fees may be included where those fees are clearly linked to the scope of the
project.
Fees that are outside of the scope of the project must not be included within the
refurbishment cost. For example, in-house costs such as service management or
administration. These are deemed to be operational costs and therefore are not eligible to be
included within the refurbishment cost.
If when reviewing the supporting statement and supporting evidence the assessor
determines there is a notable degree of difference between the scope of refurbishment work
and the stated/estimated refurbishment cost, the assessor will seek clarification from the
applicant regarding the work and associated costs.
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ix.
What constitutes ‘fire safety improvements’?
For the purposes of the higher accommodation supplement, fire safety improvements are
defined as the installation, alteration or upgrading of any of the following fire safety features
in a residential care service:
a) Fire sprinkler system inclusive of tanks, pumps and mains etc. as applicable,
b) Fire hydrant system inclusive of tanks, pumps and mains etc. as applicable,
c) Fire hose reel systems,
d) Fire extinguishers,
e) Smoke detection and alarm system inclusive of fire indicator panel, break glass
alarms, annunciator panels etc. as applicable,
f)
Emergency lighting systems,
g) Exit signage systems.
Fire safety features that are incorporated into the design, configuration and construction of
the building (i.e. tangible structural building features) are not included in the definition of fire
safety improvement. For example:

Fire ratings to walls, floors, and ceilings;

Smoke walls (including doors and windows) to achieve compliance with Building
Code Australia’s smoke compartmentalisation and construction of the building; and

Construction of exits including stairs and fire rated stair shafts, lift shafts and other
building services shafts.
x.
Treatment of fire safety improvement expenditure
Where a refurbishment project has or will include fire safety improvements, there is a cap on
the amount of expenditure relating to these improvements that can be included in the
refurbishment cost. This cap is equivalent to 25 per cent of the calculated minimum
monetary spend amount. Expenditure relating to fire safety improvements up to and
including the value of the cap can be included in the refurbishment cost.
Where the expenditure relating to installing fire safety improvement is greater than
25 per cent of the minimum monetary spend amount, the refurbishment cost is calculated
using the following formula:
Refurbishment cost = A – (B – C), where:
A is the total cost of the refurbishment
B is the cost of the fire safety improvements
C is the amount that is 25 per cent of the minimum monetary spend amount in relation to the
service.
The assessor will compare the eligible refurbishment cost amount to the minimum spend
amount to verify section 52(2)(h) or 53(2)(g) of the Principles has been satisfied.
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xi.
Costs capitalised as per Australian accounting standards
The relevant costs of the refurbishment project must be capitalised in accordance with the
Australian accounting standards. Relevant costs are those which relate to structural
improvements or other costs that can be depreciated because they relate to fixtures, fittings
or anything that can be removed intact.
Sections 52(2)(e) 53(2)(d) of the Principles require the applicant to commit to capitalising the
relevant costs of the refurbishment in accordance with the Australian accounting standards.
If the applicant’s response to this item is ‘Yes’, no further assessment action is required, if
the applicant’s response to this item is ‘No’ the assessor will seek further information from
the applicant.
xii.
The Supporting Statement
At a minimum, applicants are required to provide with their application the information
specified under the Supporting Statement section of the application form.
When reviewing the supporting statement, the assessor will consider:

the work that has been/will be undertaken to benefit care recipients;

the differences in form, function and quality that have been made/will be made to the
service as a result of the refurbishment;

the proportion of the refurbished facility which is/will be accessible to, and for the use
of, eligible residential care recipients;

any areas that have been/will be refurbished that are not for the use of care
recipients;

the significance of benefits to eligible care recipients as a result of refurbishments
made to care recipient rooms and common areas.
If after reviewing the supporting statement and any other information provided, the assessor
concludes insufficient information has been provided to determine if the eligibility criteria
have been/will be met, further information will be sought.
xiii.
The Supporting Evidence
Pre–Approval
Applicants are required to provide relevant proposed site, floor and/or building plans with
their application. The assessors will use this material to confirm that the proposed
refurbishment (as described in the supporting statement) is readily discernible and
demonstrates a significant enhancement of amenity and accommodation for care recipients.
If the submitted plans do not clearly identify the proposed refurbished areas, further
information, including submission of plans that visibly identify the changes to be made to the
service, may be sought.
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Standard Approval
Applicants are required to provide a certificate of occupancy (or equivalent), if relevant and
final site or floor building plans with their application. If these documents are not provided,
the assessor will request the applicant submit these documents to enable an assessment of
their application to be completed.
Some refurbishment projects may not require a local authority to issue a certificate of
occupancy; if that is the case the requirement to provide a certificate of occupancy can be
waived by the assessor. However, an alternative form of evidence confirming the completion
date will be required from the applicant.
For the purposes of verifying whether Section 52(2)(a) of the Principles has been met, the
date of issue of the certificate of occupancy is taken to be the completion date of the
refurbishment project. To satisfy Section 52(2)(a) of the Principles, the date of issue of the
certificate of occupancy (or equivalent) must be on or after 20 April 2012.
Due to varying state and local government practices, there may be some variation in the
format and content of these documents. Assessors will determine if the document provided
by the applicant relates directly to the refurbishment project for which the significant
refurbishment determination is sought, and that the date of completion of that work is
indicated on that document.
The applicant is also required to provide site, floor and/or building plans. The assessor will
use this material to confirm that the proposed refurbishment (as described in the supporting
statement) is readily discernible and demonstrates a significant enhancement of amenity and
accommodation for care recipients.
If plans do not clearly identify the refurbished areas, further information including submission
of plans that visibly identify those areas will be sought.
2.3.2
Confirmation of Completion of a Pre-Approved Significant
Refurbishment
Only applicants who have received pre-approval should submit a Confirmation of Completion
of a Pre-Approved Significant Refurbishment form.
The purpose of the form is for the applicant to confirm that the refurbishment of the service
has been completed, to provide the date of completion, and the refurbishment cost. In
addition, the applicant must review the information previously provided in the pre-approval
application to ascertain whether there are any material differences between the proposed
refurbishment work as described in the pre-approval application (i.e. significantly changed in
scope, quality, form, functionality, types of work undertaken, etc.), and the actual
refurbishment outcome.
Where the completed refurbishment is materially different from the pre-approved proposed
refurbishment, an outline of the key aspects of the refurbishment that have differed is
required.
In addition, if the final site, floor and/or building plans have differed materially from the
proposed plans attached to the pre-approval application, the applicant is required to provide
revised plans, which clearly identify the refurbished areas.
In cases where there is a material difference between the proposed refurbishment and the
actual refurbishment, the assessor will review the pre-approval application material and
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other supporting evidence and undertake a comparison of the work that was proposed
against that which was actually undertaken, as described in the confirmation of completion
form.
Upon review of the scope and significance of the completed refurbishment, the assessor will
determine if the refurbishment meets the eligibility criteria as defined in the Principles.
2.4.
Assessment finalisation
Prior to submitting a report and recommendations to the delegate, a peer review of the
assessor’s report is to be undertaken by another assessor.
For reports recommending the delegate determine the service to be significantly refurbished,
a high level review will be undertaken by another assessor.
For reports recommending the delegate refuse to determine the service to be significantly
refurbished, another assessor will conduct a more detailed review.
The reviewing assessor may:
1. Agree with the recommendation; or
2. Make an alternative recommendation.
Where the reviewing assessor’s recommendation is in accordance with the first assessor’s
recommendation, the reviewing assessor is to provide a brief statement attached to the
report.
Where the recommendation is a different recommendation to that of the first assessor, the
reviewing assessor will explicitly identify in the assessment report the factors of difference,
and explain how those factors lead to a different assessment outcome in their view, which is
to be attached to the report.
Following peer review, a completed assessment report is to be submitted to the delegate for
consideration.
The assessment report provides a recommendation to the delegate on the conclusions
reached by the assessor in relation to whether the applicant has satisfactorily met the
legislative requirements outlined in the Principles.
The delegate will consider the application and the assessors’ reports, and then, taking into
account the information in the application, and the analysis and recommendation(s)
contained in the report, and the individual circumstances of the application, will reach a
decision as to whether to approve the application or to refuse to approve the application.
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3. Definitions
Accommodation wing
Includes a building; a floor or level of a building; and an annex to a building that is used to
provide accommodation for a care recipient being provided with residential care through the
service.
Care recipient room
A room or part of a room intended to be occupied as personal space by a care recipient
where this includes the bed used by a care recipient and the areas immediately around the
bed.
Important: For each bedroom, the equivalent number of ‘care recipient rooms’ is
determined by the number of care recipients that can be accommodated in the room. For
example, if four care recipients share a bedroom, this is considered to be four care
recipient rooms. If one care recipient resides in one bedroom and another in an adjoining
bedroom (but with a shared bathroom), this is two care recipient rooms.
Eligible care recipients
Eligible care recipients are those in respect of whom the accommodation supplement is
payable.
For those care recipients in care before 1 July 2014, their eligibility for an accommodation
supplement is based on the asset test undertaken when they first entered care. These care
recipients are those defined as concessional, assisted or supported under clause 1 of
Schedule 1 to the Aged Care (Transitional Provisions) Act 1997.
For those care recipients entering care on or after 1 July 2014, their eligibility for an
accommodation supplement is based on the means test of their income and assets when
they first enter care. These care recipients are those defined as low-means under section 5
of the Subsidy Principles 2014.
Extension
A new and additional part of an existing care residential care service (e.g. a new
accommodation wing).
Minimum monetary spend amount
The amount worked out by multiplying $25,000 by 40 per cent of the lower of:
a) the total number of care recipient rooms in the service before the commencement of
the refurbishment; and
b) the total number of care recipient rooms in the service after the completion of the
refurbishment.
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Operational place
An operational place is one that is either occupied or available for the provision of Australian
Government-funded aged care to an approved care recipient. It does not include places that
have been approved, but are not yet operational.
Refurbishment cost
The total cost of the refurbishment, or the proposed refurbishment, of the service unless fire
safety improvements have been included in the project and the cost of such improvements is
more than 25 per cent of the minimum monetary spend amount – in these cases the
refurbishment cost is worked out using the following formula:
A–(B–C)
where:
A is the total cost of the refurbishment.
B is the cost of the fire safety improvements.
C is the amount that is 25 per cent of the minimum monetary spend amount in
relation to the service.
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