Submissions and papers

Aged Care Reform Now exists to engage constructively in the aged care reform process and influence positive change. This page lists our research reports and submissions to government as part of ongoing lobbying, and in response to invitations for community consultation.

Response to the Exposure Draft – Aged Care Bill 2023

Aged Care Reform Now has collaborated with Aged Care Justice Inc. (ACJ), Allied Aged Care, Aged Care Crisis, Carers’ Circle, Older Women’s Network NSW and the Quality Aged Care Action Group Inc to respond to the Exposure Draft – Aged Care Bill 2023.

The Draft aims to establish regulations for safe, person-centered, and rights-based aged care services in Australia. However we have the following concerns:

  • Rights Enforcement: Gaps in the Draft might hinder the enforcement of rights for the recipients of aged care.
  • Care Standards: Lack of clarity exists concerning clinical care requirements and workforce standards.
  • Governance: Issues regarding provider transparency and accountability are present.
  • Funding: Inadequate funding could make it difficult to implement changes, especially the shift towards smaller, community-based care models favored by the Royal Commission.
  • Scope: Limited to Commonwealth-funded services, the Draft leaves those receiving private aged care less protected.

Download and read our full submission below:

Response to a New Aged Care Act

The Aged Care Act that is currently in place is literally from last century (1997) and is being completely overhauled.

Aged Care Reform Now collaborated with Carer’s Circle to provide input into the new Aged Care Act as it is the foundation of a collaborative, transparent and effectively regulated aged care system that is focused on the human rights and quality of life of older people as their needs change.

Overall, we’re pleased to see that the focus of the Act has shifted from funding and providers, to the individual – however we don’t believe this has carried through to all areas of the Act under consideration. We point these out throughout this submission, starting with the key issue of the application of the Act being limited to Commonwealth funded aged care services.

This is one of many submissions in this space on the long road to reform.

Response to the Exposure Draft Medicines, Poisons and Therapeutic Goods Regulation (NSW)

Aged Care Reform Now and Carers’ Circle responded to the Exposure Draft Medicines, Poisons and Therapeutic Goods Regulation (Draft Regulation) and its Regulatory Impact Statement for New South Wales Health.

The submission promoted the importance of aged care settings as health care settings and the importance of pharmacology. It then provided four recommendations with real life examples of where medication management had gone wrong in these areas. The submission also included information from Aged Care Justice on the seven main complaints it receives due to medication mismanagement and requested that all medicines be clearly labelled with the reason for the medication.

You can download the full submission here:

Healthcare, Disability Care and the Care Workforce

Throughout Aged Care Reform Now’s engagement on aged care reform forums, submissions, and roundtables it has become increasingly clear to us that workforce issues across the care sectors have suffered systematic deskilling, downgrading and neglect, the consequences of which are being realised now.

This paper submitted for the NDIS review includes 9 recommendations to improve the education and regulation of all care workers across the care spectrum.

Response to “A new regulatory model for aged care”

Aged Care Reform Now formed a working group to respond to the Department of Health’s proposed new regulatory model for aged care as outlined in A new model for regulating Aged Care | Consultation Paper No. 2 (“Consultation Paper 2”). We were pleased to see that some of our suggestions from earlier submissions have been acknowledged and incorporated into this updated consultation paper. 

Overall, we were mostly pleased with the direction of the reform, however we were concerned that the model was still too provider centric, rather than placing older people in Australia at the front and centre of regulation, which it claimed to do.

You can read a summary of the key points in this article or download the full paper below.

Senate Select Committee into the provision of and access to dental services in Australia

The ACRN submission for the inquiry into the provision of and access to dental services in Australia was accepted for publication. You can read a summary of the submission in this article.

The published submission is available on the Senate committee’s webpage or you can download it below.

Joint submission for Inquiry into the Inspector-General of Aged Care Bill 2023

Read a summary of the submission here or download the full paper below.

Providing feedback on the Draft Inspector-General of Aged Care Bill

We joined forces with Aged Care Justice, Quality Aged Care Action Group (QACAG), and Carers’ Circle to provide feedback on the Draft Inspector-General of Aged Care Bill.

Our submission recommended amendments to the draft Bill to ensure the Inspector-General’s objectives, powers, complaints oversight, reporting and consultation, reflect the needs of the members of each organisation, and meet the intentions of the Royal Commission into Aged Care, specifically in relation to accountability, transparency, and the independence of the Inspector -General office from the Ministerial office.

You can read the paper, submitted 27 January 2023, here:

Responding to the National Dementia Action Plan, January 2023

We brought together members with lived experience of dementia – either by having it themselves, or caring for someone living with the disease – to respond to the Department of Health’s consultation paper on the National Dementia Action Plan.

Our proposed vision was:

“people living with dementia and their carers are supported to have the best life possible, free from discrimination and harm”

Our submission focused on enablement and offered suggestions around:

  • Tackling stigma and discrimination
  • Minimising risk, delaying onset and progression
  • Improving dementia diagnosis and post diagnostic care and support
  • Improved treatment, co-ordination and support along the dementia journey
  • Supporting people caring for those living with dementia
  • Building dementia capability in the workforce
  • Improving dementia data and maximising the impact of dementia research and innovation

You can read the full submission here: 

A New Program for In-Home Aged Care Discussion Paper, November 2022

The Department of Health issued a discussion paper looking at some of the key issues in the design of reforms to in-home aged care

We created a working group of ACRN members to discuss the issues raised and importantly, examine what was missing. The working group participated in some lively Zoom discussions, sent emails, shared their stories and helped draft and review the report. 

The main points raised were:

  • The need for trained independent assessors with a clinical background (similar to the ACAT workforce) with the Primary Health Networks having a greater role in the assessment process
  • The need for a technological solution to help with communication across service providers with the older person controlling access to information
  • Strong objection to the Department’s use of the term “care partners’ to describe service facilitators or managers (care should be an attribute they display – not a title)
  • Strong objection to the quarterly “use it or lose it” funding model; and lastly
  • Some of our members are hearing that non-PBS medicines will no longer be covered by home care packages – we want to put a stop to this before it starts. 

You can read the full submission here: 

Aged Care Quality and Safety Commission capability review, December 2022

The Australian Government commissioned an independent capability review of the Aged Care Quality and Safety Commission. The review is in response to the Royal Commission recommendation 104.

ACRN provided a submission as part of the public consultation process.

ACRN believes the current model creates role conflict and a lack of capacity of the regulator to focus on the care of individuals. The promotion and provision of incentives for existing Providers to meet and improve on quality standards, audit and accreditation requires a different approach and conflicts with complaints management and community education. All these functions should not be delivered by one agency.

Our full response can be downloaded below:

Pre-budget submission, October 2022

Aged Care Reform Now’s (ACRN) Budget submission was decided on as part of our lobbying for systemic reform. The change of government raised concerns regarding the progress of aged care reforms and the direction such reforms will take. Members were particularly concerned about the continually worsening staffing and skills crisis in residential aged care.

Treasurer Jim Chalmers stated the October 2022 Budget would be a “bread and butter budget” which would find cost savings and deal with basic needs. Although Government is determined to progress its 5 basic aged care reforms, including 24/7 Registered Nurses, members were concerned that ongoing reforms at the aged care recipient level would not progress in the near term.

We outline what the priorities should be in this paper.

Designing a new approach to regulating Aged Care, October 2022

ACRN does not believe the framework proposed in “A new model for regulation Aged Care Consultation Paper No.1”, will ‘shift the dial’ and result in significant improvements to the aged care sector needed to keep older Australians safe.

This submission is in response to part 2 of the Health Department’s consultation process on designing a new regulatory framework.  

ACRN believes a new aged care regulatory framework should: 

  1. Support the implementation of human-rights based legislation
  2. Compel providers and aged care staff to act lawfully and deliver the services they are contracted to deliver through prescribed penalties
  3. Encompass a rigorous complaints system and outline the standards and expectations for complaints resolution in the aged care sector
  4. Include mechanisms for sharing of medical and other information with families and across agencies
  5. Outline roles and responsibilities for the regulator, providers, government agencies, health care practitioners and aged care staff to protect consumers
  6. Provide information and standards regarding investigations
  7. Provide standards for information and data collection, reporting and transparency within the aged care system, including appropriate public reporting on breaches, complaints and performance
  8. Provide standards for accreditation and re-accreditation

Joint submission to the Productivity Commission on its Carer leave issues paper, August 2022

In collaboration with the Quality Aged Care Action Group and Carers’ Circle, Aged Care Reform Now (ACRN) provided a joint submission to the Productivity Commission on its Carer leave issues paper. The submission discussed the provision of carer leave and importantly the other support services that impact the need for carer leave provisions and entitlements. Essentially, if there were better support systems in place to help people stay at home, there would be less need for carers to take time out of the workforce. 

This is the first step in the discussion with another submission due early 2023. 

13 questions – ‘where do you stand on aged care?’ research paper September 2022

Aged Care Reform Now ran a survey and letter-writing campaign for the 2022 Federal Election where we asked everyday Australians, electoral candidates, and Members of Parliament about where they stood on aged care reform.

The research showed significant support for aged care reform in the key areas of quality care, workforce, transparency, and accountability. But, it also showed that many people were not across the key issues older Australians and their support network face. 

Aged Care Reform Now Workforce Strategy, February 2022

The ACRN team, using lifetimes of nursing, allied health and people management experience, have produced a staged workforce strategy. This strategy offers practical solutions to arrest staffing losses, and sets practical solutions as first steps to real reform.

“Have a bias towards action – let’s see something happen now. You can break that big plan into small steps, and take the first step right away”

— Indira Ghandi

The federal government has announced yet another investigation into the deaths and staffing crisis in aged care. ACRN believes 20+ inquiries and a Royal Commission are enough. This paper is being sent to every Federal parliamentarian and we will report back on the responses in our news section, in our private Facebook group, and on our public Facebook page. The time to ACT is Now!

Aged Care Reform Now response to Development of Star Ratings and quality indicators for residential and home care, December 2021

Aged Care Reform Now response to Serious Incident Response Scheme (SIRS) for in-home aged care services, August 2021

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