Aged Care Legislated Review – Baptist Care Australia
Table of Contents
1. Tell us about you 2
1.1 What is your full name? 2
1.2 What stakeholder category do you most identify with? 2
1.3 Are you providing a submission as an individual or on behalf of an organisation? 2
1.4 Do you identify with any special needs groups? 2
1.5 What is your organisation’s name? 2
1.6 Which category does your organisation most identify with? 2
1.7 Do we have your permission to publish parts of your response that are not personally identifiable? 2
2. Response to Criteria in the Legislation 3
2.1 Whether unmet demand for residential and home care places has been reduced 3
2.2 Whether the number and mix of places for residential care and home care should continue to be controlled 3
2.3 Whether further steps could be taken to change key aged care services from a supply driven model to a consumer demand driven model 4
2.4 The effectiveness of means testing arrangements for aged care services, including an assessment of the alignment of charges across residential care and home care services 4
2.5 The effectiveness of arrangements for regulating prices for aged care accommodation 7
2.6 The effectiveness of arrangements for protecting equity of access to aged care services for different population groups 7
2.7 The effectiveness of workforce strategies in aged care services, including strategies for the education, recruitment, retention and funding of aged care workers 7
2.8 The effectiveness of arrangements for protecting refundable deposits and accommodation bonds 8
2.9 The effectiveness of arrangements for facilitating access to aged care services 8
3. Other comments 10
1. Tell us about you
1.1 What is your full name?
-
1.2 What stakeholder category do you most identify with?
Peak body - provider
1.3 Are you providing a submission as an individual or on behalf of an organisation?
Organisation
1.4 Do you identify with any special needs groups?
Nil
1.5 What is your organisation’s name?
Baptist Care Australia – on behalf of and with input from member groups
1.6 Which category does your organisation most identify with?
Aged Care Peak Body
1.7 Do we have your permission to publish parts of your response that are not personally identifiable?
Yes, publish all parts of my response except my name and email address
2. Response to Criteria in the Legislation
2.1 Whether unmet demand for residential and home care places has been reduced
Refers to Section 4(2)(a) in the Act
In this context, unmet demand means:
• a person who needs aged care services is unable to access the service they are eligible for
e.g. a person with an Aged Care Assessment Team / Service (ACAT or ACAS ) approval for residential care is unable to find an available place; or
• a person who needs home care services is able to access care, but not the level of care they need
e.g. the person is eligible for a level 4 package but can only access a level 2 package.
Response provided:
HOME SERVICES
Within Home Services there continues to be significant unmet demand for Level 3 and 4 packages even with the release of the last ACAR round. BCA Members are currently experiencing the highest vacancy in Level 2 packages ever experienced. Two key factors appear to have impacted on this outcome. The introduction of Income Tested Fees has resulted in self-funded retirees opting out of accepting a Level 2 package as it is more cost effective to source private services. In addition, additional funding released through CHSP has resulted in consumers accessing multiple CHSP supports over a Level 2 package with a lower and non-standard client contribution. Level 1 packages continue to be a challenge as consumers do not see the value when client contribution is the same as Level 2, 3 and 4. It is expected that a National Waitlist will enable DoH to assess this further to determine if the current split of packages across levels is appropriate or if this needs to be considered further particularly whether the subsidy rates for the 4 levels are appropriate or if this needs to be re-evaluated.
RESIDENTIAL AGED CARE
While we don’t have long wait lists in RAC suggesting that unmet need isn’t a problem, this could however be a reflection of the number of places in the regions we operate in and a reflection of the need of prospective residents (since many people enter RAC in crisis).
2.2 Whether the number and mix of places for residential care and home care should continue to be controlled
Refers to Section 4(2)(b) in the Act
In this context:
• the number and mix of packages and places refers to the number and location of residential aged care places and the number and level of home care packages allocated by Government; and
• controlled means the process by which the government sets the number of residential care places or home care packages available.
Response provided:
HOME SERVICES
With issues detailed in Q2.1 for Home Services, it would be beneficial to consider a pool of funding and releasing funding according to current need. For example, it could be that rather than a large volume of Level 2 packages remaining vacant that some of this funding is released to Level 3 or 4 packages.
RESIDENTIAL AGED CARE
From a provider view it’s possible that the control is good, from A customer lens, that may not be the case in terms of them finding the best product and providers having to be more highly tuned to market demand to remain competitive in an uncontrolled market.
2.3 Whether further steps could be taken to change key aged care services from a supply driven model to a consumer demand driven model
Refers to Section 4(2)(c) in the Act
In this context:
• a supply driven model refers to the current system where the government controls the number, funding level and location of residential aged care places and the number and level of home care packages;
• a consumer demand driven model refers to a model where once a consumer is assessed as needing care, they will receive appropriate funding, and can choose services from a provider of their choice and also choose how, where and what services will be delivered.
Response provided:
HOME SERVICES
There remains the reality that the available funding pool to support aged care will always need to be carefully managed. The introduction of a consumer demand driven model needs to be carefully considered to ensure it is best model and approach for Australia. BCA Members support the introduction of consumer directed care and empowering the consumer to take control. We would however suggest that the model needs to be further bedded down and considered before any further changes are made. The experience of international models of consumer directed care many of whom have been through much iteration since they were first introduced shows that careful thought needs to be given. Australia has the opportunity now to properly assess and make improvements where issues are identified. There has been significant changes made over a short period of time and many of the systems introduced are not performing at the level they need to be for the full implementation of a consumer demand driven model (e.g. DHS Payment Systems, certain aspects of RAS and MAC). A time to reassess and re-evaluate would be welcomed.
RESIDENTIAL AGED CARE
More detail / assistance would be helpful for a start in RAC. Always troubling in RAC because of our fixed overheads; which part of the funding would be consumer directed?
2.4 The effectiveness of means testing arrangements for aged care services, including an assessment of the alignment of charges across residential care and home care services
Refers to Section 4(2)(d) in the Act
In this context:
• means testing arrangements means the assessment process where:
o the capacity of a person to contribute to their care or accommodation is assessed (their assessable income and assets are determined); and
o the contribution that they should make to their care or accommodation is decided (their means or income tested care fee, and any accommodation payment or contribution is determined).
Response provided:
HOME SERVICES
The introduction of mean tested fees has added significant administration for service providers and DHS. While BCA Members fully support means testing, it considers that the process can be simplified for consumers, service providers and DHS. Income Tested Fees currently require an initial assessment and then ongoing quarterly reviews. ITF are then reviewed in monthly claim to ensure consumer is charged and then reconciled with payment statement to ensure data is correct. There has continued to be ongoing issues with ITF letters (in some instances consumer and approved provider will receive 3 letters with different amounts) and often there is a long delay before initial assessment is completed which accumulates a large debt for the consumer. With a move to a consumer driven market, it would be beneficial to consider that any consumer who is assessed as required to pay an ITF has their subsidy adjusted accordingly and this becomes their pool of government funding. The consumer can then choose whether they would like to contribute more to their care if the subsidy received does not fully support their needs (i.e. fee for service). This way, the need to reconcile ITF monthly is not required which saves considerable amount of time and complication for all parties.
RESIDENTIAL AGED CARE
It has had teething problems (further detail to follow from Tim). From the consumer point of view, for many it’s an onerous part of the aged care journey. Aged care is considered very expensive.
Summary of changes 1 July 2014 Residential Aged Care Commencing 1 July 2014 all permanent RAC residents are subject to an income and assets test (means test) by Centrelink/DVA. Residents with income and/or assets over certain thresholds are required the pay the means-tested care fee (MTCF). The MTCF is capped at the cost of care (up to the maximum daily rate of ACFI, currently $214.06, ignoring oxygen and enteral supplements). The Commonwealth reduces the care subsidy paid to the provider by the same amount as the assessed MTCF, meaning some residents pay in part or in full for the cost of their care. There is an annual cap (currently $26,041) and a lifetime cap (currently $62,498) after which a resident pays no further fees that year (for the annual cap) or ever, when they reach the lifetime cap. Fees paid to previous providers, including for In Home Care are included in the annual and lifetime caps. If the annual cap is reached, the MTCF drops to zero for the rest of the year, dated from the anniversary of admission and the Commonwealth pays the full ACFI for that resident from that date. If the lifetime cap is reached the resident will no longer pay any MTCF and the Commonwealth will pay the full ACFI for that resident until they are discharged. The caps are indexed, and the resident needs to reach the latest indexed cap before the fee ceases. The fees are reviewed each quarter for all residents based on information provided to Centrelink/DVA. If their means have changed, their MTCF is adjusted accordingly. If their means were reduced during the previous quarter, they may be given a refund for an overpayment of the MTCF. Residents admitted prior to 1 July 2014 were subject to an income test (assets were ignored), and residents with income over a certain level were required to pay an Income Tested Fee (ITF). As with the MTCF, the subsidy payable to the provider is reduced by the amount of ITF. The maximum daily ITF payable is currently $76.94. There is no annual or lifetime cap. The maximum amount is indexed. In Home Care Commencing 1 July 2014 all In Home Care residents are subject to an income test similar to the now defunct Income Tested Fee for RAC. The care subsidy is reduced by the same amount as the ITF. This fee is also subject to an annual and lifetime cap, and is counted towards the MTCF lifetime cap in RAC. Clients commencing prior to 1 July 2014 were not subject to any means testing by the Commonwealth. This submission focuses on our experience of the MTCF in residential aged care, although some of the observations and recommendations will also relate to in-home care. Issues with notifications of the MTCF There are several ways the notification of the MTCF could be improved. The notifications are only done by printed letters through the post, one to the provider and one to their resident or representative. (Recommendation 1) The provider should have the option to receive MTCF notifications electronically. This will reduce the considerable cost of the mail-out, eliminate the possibility of individual letters being lost and allow for the faster delivery of the information. There are long delays associated with the notification of the outcome of the quarterly reviews. The letters are generally received at least a month after the review date, which means fees for prior months have to be backdated and re-charged at a different rate. This adds to the workload of the provider, adds to the complexity of invoices sent to residents and increases the chance that large adjustments are made to accounts sometime after a resident has died or left the service. (Recommendation 2) The Review investigates the quarterly MTCF review process to suggest efficiency improvements.