COTA Australia regards the draft Standards Guidance as a comprehensive guide to the delivery of the core standards which focus not only on the quality of care and safety standards expected of services, but also on the delivery of services that meet the ‘quality of life’ expectations of consumers and carers. Of particular importance is that the Standards Guidance materials will identify how an aged care provider will be assessed on delivering the eight ‘consumer outcomes’ as they apply to each of the organisational requirements as well as the relevance of the Consumer Experience Reports (CER) as they pertain to specific standards areas including how the interviews and CER’s collected from consumers will be considered as part of the Standards Guidance Material.
Based on feedback, from a consumer perspective the Standards Guidance Materials do not explain how the standards will be monitored and enforced. We would urge the Agency/Commission to ensure explanatory information specifically for consumers is included within any area where the materials on the standards are provided.
We welcome the introduction of a risk based approach identified in the introductory section of the Guidance materials, including consideration of effective quality systems. We recognise these introductory remarks also discuss that the standards allow a quality assessor to monitor processes to focus on ‘consumer outcomes’ but we are concerned that this distinct and measurable concept, as outlined in the proposed standards, has been blended with the much broader and further reaching concept of ‘consumer experience’. While we recognise the benefits of incorporating consumer experience into the assessment process, the materials must not do so in a way that diminishes the principal role of the Consumer Outcome Statements.
We would propose a clear definition, outlining the purpose of the Consumer Outcome Statements, the Organisation Statement and the Requirements, is included in either the introductory or definitions section. Should the concept of ‘consumer experience’ also be retained within the materials a clear definition should also be included. COTA’s view is that consumer experience is broad and should encompass more than ‘satisfaction’ or ‘quality of life’, but we recognise that within the sector there is a range of views as to how far ‘experience’ should be considered. Without a clear and common understanding within the sector of the role of the Consumer Outcomes (and the Organisation statement), COTA is concerned that the future of the standards will inappropriately focus solely on the assessable requirements and diminish the purpose of the outcome and organisational statement.
COTA is further concerned that the guidance materials are too long and complex. The guidance acknowledges on page 2 that it ‘does not cover all possible strategies or sources of evidence that could be used by an organisation’ and that ‘each organisation should interpret the guidance considering its own service delivery model’. Furthermore, it suggests ‘outcomes, and the manner in which they are demonstrated, will be unique to individual services’ responses to their consumers’ needs’. Consultations conducted with consumers identified that consumers are happy with the intent and direction of the Guidance Material but felt the language is not appropriate for on the ground staff to understand.
There are concerns by consumers that the guidance materials provide a lack of clarity on the way these will be implemented, measured and assessed. COTA understands the difficulty in creating guidance materials that can be used by aged care organisations of varying size and structure. Nevertheless, it is concerning that, because the guidance is too broad and lacks a clear structure, the obligations on providers could become lost. It is worth noting that Victoria is in the process of developing a set of performance measures for its Public Sector Residential Aged Care Service providers. Once finalised, this might be a useful resource to be included in the materials.
The materials would also benefit from more work to improve readability and to make them more accessible and user-friendly for a range of staff and stakeholders. This could entail moving some of the material into supporting appendices.
COTA welcomed ‘Consumer dignity and choice’ as a new standard and considers this should be used to provide an overarching framework for the delivery of services which would be welcomed by service recipients. Indeed Standard 1 fits well with consumer expectations around ‘quality of life’ measures and is described as a ‘foundation’ standard. However, the current draft Guidance materials fail to create or clearly demonstrate the link between Standard 1 and the remaining standards. It should, in our view, be made more directly obvious that other standards cannot be met unless in doing so there is full compliance with Standard 1. This is particularly evident in the area of responding to diversity. COTA is concerned to hear that providers appear to lack capacity to respond to diversity and that quality assessors do not feel equipped to assess how providers are responding to this need.
There is some ambiguity in the Guidance materials about the term ‘consumers’ (notably in the definition on page 4) and when this includes a person’s representative, carer, family member or substitute decision maker or not. This is of particular concern when COTA hears that often relatives are being kept out of the loop, especially when this occurs in residential care where consumers may be experiencing cognitive decline, or have language differences or speech difficulties. A clear definition of ‘who is the consumer’ should be included within the materials in a way that ensures the focus is provided to the aged care resident or client, but recognises when it may be appropriate to include the substitute decision maker, family/friends or other representative.
COTA Australia is pleased to see consumers are expected to be involved in the planning, design, delivery, measurement and evaluation of services and that this expectation is incorporated into the guidance materials. However, this seems to be mostly in relation to the care and services they receive as an individual and the customer/consumer ‘voice’ as a whole seems to be missing from the materials. COTA would have expected to see the materials set a methodology for the aged care sector to work more systemically and systematically with consumers to build a more responsive and effective aged care system across the board and not just in the individual delivery of services. We believe consumers and providers would welcome best practice ideas from the new Commission on how to build and deliver effective consumer partnerships and propose that this be an addition to the guidance materials. This could also help consumers better understand how they can work together with providers to create change within their organisation.
Similarly, the guidance is largely silent on strategies to help consumers to improve their health literacy and build their understanding and capacity to support organisational and service sector design. COTA believes consumers would welcome training and support from providers in this area.
Finally, the guidance materials seem heavily geared towards residential aged care services with little explicit or obvious consideration of what guidance materials are required in a community or home care setting. While COTA appreciates the historical context and that bringing community and home care providers into a new compliance regime is a complex change process, we believe these standards and their materials need to be developed in a manner that reinforce change and improve service delivery for the whole of the aged care service system. While some standards will be similar across the service settings (e.g. Human Resources) others require specific consideration for the service settings in which they are performed (e.g. personal care and clinical care). Strategies and ideas for either home care or community care as distinct from residential care would be helpful within the Guidance materials to ensure these providers have the tools and resources necessary to fully meet their requirements.