Tanya Austin-Howell - Northside Community Forum Inc
21 December 2012
Ms. Kerrie Westcott, Director
Legislation Section, Transition Branch
Ageing and Aged Care Division
MDP 550, GPO Box 9848
Canberra ACT 2601
Dear Ms. Westcott,
Re: Feedback re proposed changes to the Aged Care Act 1997
Please find attached a report from community care industry representatives working in the
Northern Sydney region presenting their feedback, comments and suggestions on the proposed
changes to the Aged Care Act 1997.
We hope that this information will be taken into account when considering the changes to the
legislation.
If you have any questions or would like more information please contact the HACC
Development Officer, Mrs Tanya Austin-Howell on 02 8405 4444 or haccdo@nsforum.org.au
Sincerely
Irena Liddell
Executive Officer
1. Introduction
In November 2012 the Department of Health and Ageing released an Overview Paper on the
proposed legislative amendments to the Aged Care Act 1997 and related legislation.
The Overview paper has been prepared by the Department of Health and Ageing as a basis for
consultation with consumers of aged care services, the aged care industry and the general public
regarding legislative amendments required to implement the Living Longer Living Better
package of aged care reforms that were announced on 20 April 2012.
Northside Community Forum Incorporated, through the Northern Sydney Home and Community
Care (HACC) Development Project facilitated a forum of local service agencies to seek
comment on the proposed changes to the Aged Care Act 1997. As these changes will lay the
foundation for much of the Government's aged care reform package the proposed changes to the
legislation are likely to have impacts on the Commonwealth Home Support Program and the
work of the HACC funded agencies. Six community care providers within the Northern Sydney
region (referred to as 'the group' in this report) attended this forum and have collectively
provided the feedback below.
Key Areas of Focus
The aged care reform package Living Longer Living Better has direct impact on the provision of
HACC and home support services. Because the proposed legislative changes to home support
services will also have the most bearing on HACC services, the group chose to focus attention on
the changes in this area. There was also attention given to the proposed changes involving
Governance and Administration.
Organisations
The organisations involved included both HACC and non-HACC services.
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Catholic Community Services NSWjACT
Community Care Northern Beaches Limited
Diverse Community Care
North Ryde Community Aide & Information Centre Inc.
Northside Community Forum Inc.
Uniting Care Ageing
This report presents feedback and suggestions gained at the workshop held on 15 December
2012 and covers:
1.
2.
3.
4.
5.
6.
Reference to "Home Care as a replacement for Community Care
The introduction and implementation of four levels of Aged Care Packages
The introduction of a Behaviour Supplement (Dementia) and Veteran's Supplement
Income testing
Governance and administration
General comments about the impacts of the Aged Care Reforms
2. Proposed Changes to Care at Home
2.1 A new type of care, Home Care will replace Community Care
Changing the name of Community Care to Home Care will create confusion with consumers as
Home Care is the name which is currently used when referring to the Aging, Disability and
Home Care program The Home Care Service of NSW. It is also the term commonly used in the
industry when referring to a collection of services including domestic assistance, personal care
and respite. Furthermore, many organisations use Home Care in their business name. The impact
this confusion will have is that consumers may not know what service they seek or even whom
to call.
A further source of confusion for consumers may lie in the presumption that Home Care services
are only provided in the home as opposed to Community Care which suggests a variety of
settings. This may limit consumers choice and limit them enquiring about Home Care because
they perceive that those services are only provided in the home. People may be unable to access
community services such as transportation, day centres and social groups because of this
misunderstanding.
We acknowledge that the reforms will use the term "Home Care" throughout the legislation and
the group would like to raise the issue that by doing so, a great amount of confusion is likely to
occur not only among consumers but also among service providers.
2.2 There will be four levels of home care packages and existing care packages currently
delivered as CACP, EACH, and EACH-D will transition to home care packages
New care recipients who wish to access home care on or after 1 July 2013 will require
"approval" in order to access this care. Exactly who will be providing the approval is not stated
in the proposed changes. Additionally, there is no provision made for those consumers currently
on waiting lists awaiting a CACP, EACH or EACH-D package. Many of these consumers
unfortunately have been on waiting lists for months and sometimes years and it is unclear if they
will have to be re-assessed for eligibility. If re-assessment is a requirement for eligibility,
consideration will need to be made to prioritize these consumers for approval.
The group suggest flexibility to move between the different levels of service. It is not clear for
example how a level 1 package consumer could receive level 3 supports if needed following a
severe illness and then transition back to level 1 once recovered. Assurances will need to be in
place so that the original level 1 package is still available for this type of consumer once
recovery is achieved.
As of 1 July 2014, the Commonwealth has provided no further funding for case management and
the consumer directed home care packages have no specific provision for this service as well.
Case management for many service users and especially for those from CALD backgrounds is
vital to ensuring the best utilization of services and for maintaining their independence at home.
We know from experience that consumers benefit from case management but are concerned that
they will not choose this as a support when making specific care choices. In our opinion, the
currently proposed system devalues case management and we suggest that a percentage of each
package include a case management component.
2.3 Behaviour Supplement (Dementia Supplement)
Questions have arisen regarding the determination of a dementia diagnosis for the purpose of
receiving the behaviour supplement. According to the World Alzheimer Report 2011, less than 1
in 4 people with dementia globally receive a formal diagnosis. If a medically confirmed
diagnosis of dementia is required, this may hinder eligibility because not all consumers seek
medical diagnosis for various reasons including fear of the stigma related to the disease. We
would suggest that flexibility in the determination of eligibility for the behaviour supplement be
considered.
The proposed legislation also does not indicate how the 10% will be calculated; will it be
determined on the total dollar value of the package? By factoring the supplement on the dollar
value of the package, it is questionable whether 10% in additional funds will be sufficient to
cover the additional services required by some consumers with dementia. For example, a
consumer with dementia who exhibits one behaviour will require far less services than a
consumer with dementia who is exhibiting a complexity of behaviours.
2.4 Veteran's Supplement
Clarification regarding the veteran's supplement is needed. In the summary of proposed changes
it is stated that care recipients who are veterans will receive a supplement if the care recipient has
an "acceptable mental health condition." Specification on how a mental health condition will be
determined is required. As with the dementia supplement, if a medically confirmed diagnosis is
required, this may hinder eligibility as not all consumers seek a medical diagnosis for various
reasons including the fear of the stigma related to having a mental illness.
Further clarification is sought regarding if this supplement is independent of other veteran's
support programs and also if it can be received in combination with the dementia supplement or
if it is an alternative to the dementia supplement.
Again it is unknown how the 10% supplement will be calculated and if it will meet the costs for
additional care for a veteran with a mental health condition.
2.5 Income Testing
Overall the group is in favour of fairer means testing arrangements for home care packages and
see it as a step towards equity and consistency. However, we would suggest that there be clarity
of who will be responsible for assessing an individual's financial ability to pay. Will it be the
service provider or a government department?
There may be a reluctance and fear by some potential consumers to provide financial
information, especially many from CALD communities. Having to disclose financial information
as a requirement to receive services may prevent some from seeking assistance.
2.6 Governance and Administration
2.6.1 Aged Care Pricing Commissioner
Clarity regarding how the Aged Care Pricing Commissioner will determine the amounts an
approved provider can charge a care recipient is needed.
When determining amounts charged, the group suggests that provisions be made for
rural/regional differences.
2.6.2 Australian Aged Care Quality Agency
The group suggests that the Community Care Common Standards be included in Principles as
the Standards against which Home Care will be accredited.
Additionally when setting the cost for accreditation review, we request that organisational size
and structure be taken in to account.
3. Additional Concerns
Points for consideration relating to the Aged Care Reforms:
3.1 Currently consumers are waiting to access HACC services like domestic assistance and
personal care and have been placed on waiting lists. If these services are to be included in a
package level, then consideration needs to be given to ensure that enough packages are made
available to meet the high demand.
3.2 It is unclear where specialized services fit into this model of care such as Meals-On-Wheels
and Centre-Based Day Care.
3.3 While there is a dementia supplement and a veteran's supplement available, there is no
supplement available for consumers who are not veterans that have a mental health issue. This
gap may impact on services provided to consumers who do not fit eligibility requirements for the
two existing supplements but still require additional services because of a mental illness or
chronic condition.
3.4 With the proposed new home care system, it now appears that the consumers, who would
normally have accessed basic care services through HACC, will now be eligible for a Level 1
package. These newly eligible consumers create the need for additional assessments which could
lead to a potential strain on the system. Research shows that consumers experience prolonged
independence in their own homes when they receive basic care services such as domestic
assistance. Therefore it will be imperative that timely assessments occur and that the delay
between enquiry and service provision is minimal.
3.5 It is unknown how service pricing will be determined. If it is based on market price, regional
variations in costs will need to be considered.
3.6 The changes impacting the fees paid does appear to make payment of home care services
more fair however, this could potentially lead to some unforeseen consequences. Some providers
may choose to be more selective in whom they accept as new consumers possibly only favouring
consumers willing to pay the "other agreed amounts" for services provided. Additionally, there is
the potential to delay a consumer's transition to another level of care for fear the provider will
lose the additional funds a consumer may be paying.
3.7 There are concerns, especially for the small service provider regarding payment for services.
Currently providers receive government funds in advance of service provision and are able to
budget accordingly. In the currently proposed system, providers will presumably be reimbursed
after a service has occurred. There will also be anticipated delay from when a consumer exits a
service and a new consumer starts. With the proposed new method, cash-flow problems are
probable which could have an unfavourable impact on the provider's viability.
3.8 New accounting and reporting systems are likely to require new or upgraded IT systems.
These new systems can be costly and can drastically impact the budgets of service providers,
especially the small not-for-profit provider. Additional support will be needed to assist service
providers during the transition.
The group would like to thank the Department of Health and Ageing for the opportunity to
provide comment on the proposed legislative changes. If further information is required please
contact the group facilitator.
Tanya Austin-Howell
Northern Sydney HACC Development Officer
Northside Community Forum Inc.
PO Box 564, St. Leonards NSW 1590
Lvl 3, 1 Chandos St, St. Leonards NSW 2065
P: [02] 84054400
E: haccdo@nsforum.org.au