Have you considered the impacts?

The Exposure Draft Quality of Care Principles 2014 (“Principles”) containing the extensively negotiated list of specified care and services have now been released. Although still in draft, the Principles provide a strong indication of what the final set of specified care and services which take effect on 1 July 2014 will look like. 

In broad terms, the new set of specified care and services will have three main implications. First, providers will need to consider this list in determining what care and services to offer as additional services accounting for the fact that the items in Part 3 of the list must be offered to certain residents free of charge while others may be asked to pay for these same services.   

Secondly, providers used to dealing with the old high care/low care distinction in terms of the services they offer to residents will now need to work with a distinction based on ACFI classification. Finally, the inclusion of enrolled nurses on the list of those who can provide nursing services will enable providers to reconsider their staffing models.

Abolition of high care/low care distinction

With the abolition of the high care/low care distinction, the Principles no longer distinguish between services that are to be provided to high care residents as opposed to low care residents. All residents must be provided with the care and services as required listed in Parts 1 and 2. However, there is now a distinction between residents based on their ACFI classification for the purposes of the care and services in Part 3 which includes items ranging from mobility devices, toileting and continence products, nursing services and therapy services.

Specifically, a resident whose classification level is a high ADL domain category, high CHC domain category, high behaviour domain category or a medium domain category in at least two domains or who were classified as a high level care recipient in March 2008 must be provided with the care and services in Part 3 at no additional charge. Residents who do not meet this criteria may have to pay for the care and services listed in Part 3.

Nursing services

Currently the specified care and services require that “initial and on-going assessment, planning and management of care for residents [be] carried out by a registered nurse”. Registered nurses (along with other health professionals defined to include “medical practitioners, stoma therapists, speech pathologists, physiotherapists or qualified practitioners from a palliative care team”) are also required to deliver all other nursing services within an aged care home which ranges from the development of pain management programs, catheter care, stoma care, wound management, infection management, suctioning and the administration of oxygen therapy among others.

From 1 July 2014, enrolled nurses and nurse practitioners will also be able to provide these services, provided they work within their scope of practice. According to the Department, this reflects the “modern quality of care and nursing practices”. [1]

Aged care providers will no doubt welcome this change as it will increase the flexibility in their staffing models. However providers seeking to rely on enrolled nurses will need to ensure they have robust competency assessment systems in place to ensure they can demonstrate that their staff are working within their scope of practice.


Under the current specified care and services, providers must provide “basic pharmaceutical supplies” including analgesia, bandages, creams, dressings, laxatives and mouthwashes among other items to residents free of charge.  Providers will still be required to provide “bandages, swabs, dressings and saline” as part of the delivery of treatments and procedures. However, based on the current list of specified care and services, it appears that providers will no longer be required to provide basic pharmaceuticals such as analgesia and laxatives.

Should residents require such items, it appears they will be required to purchase them either through prescription or through the provision of additional services.  Providers will need to consider how these items are provided and how they will ensure that they are accountable for the additional expenditure.  Residents and their families will (quite legitimately) want to ensure they are only paying for the items that they are using and that they are not doing so unnecessarily. Ensuring that this occurs may require a cultural shift in terms of ensuring staff properly document the use of each item so providers will need to train their staff on the importance of clear and accurate documentation of these items.

Oxygen and oxygen equipment

Oxygen and oxygen equipment have now been removed from the list of specified care and services. It is unclear whether this is intentional. According to a document released by the Department in April this year, this item has been included in item 3.8 in Part 2 of the Principles.[2] This list includes items that providers can charge for, depending on the residents’ ACFI classification.

However, the only reference to oxygen in item 3.8 (nursing services) is to “oxygen therapy requiring ongoing supervision because of a care recipient’s variable need.” This reflects the current provisions. Unlike the current provisions there is no specific reference to “oxygen and oxygen equipment”.  It is unclear whether this omission is intentional and whether the Department considers that the listing of oxygen and oxygen equipment is superfluous in light of the fact that “oxygen therapy” is specifically provided for.

At any rate, providers will need to consider how they will manage the provision of oxygen to residents who do not fall within the list of those who are to receive oxygen free of charge. Families paying for oxygen may demand the right to choose who provides the oxygen and equipment. Depending on the supplier, there may be health and safety issues associated with this. Providers will need to consider what processes they will utilise to ensure that not only are residents receiving appropriate equipment but also that the provider’s staff are safe.

Addition of basic toiletry items

Under the current regime, providers cannot charge residents for “sanitary pads, tissues, toothpaste, denture cleaning preparations, shampoo and conditioner and talcum powder”.

Toothbrushes, moisturiser, shaving cream, disposable razors and deodorants have now been added to the list. Providers should consider this when devising their list of additional services.


Although the current list of specified care and services are not yet finalised, we recommend that providers carefully review the list and determine how this will impact on their processes and practices after 1 July 2014 to ensure that they can adapt to the changes efficiently and without exposing themselves to compliance risks.