Submission to – Draft Aged Care Quality Standards and Options for Assessing Performance against Aged Care Quality Standards


COTA Australia welcomes the consolidation of the current four sets of standards for aged care services into a single set of standards for organisations providing aged care services and supports the streamlining of the quality assessment process. It acknowledges the considerable work that has been undertaken to develop simple, relevant, meaningful and measurable standards that will drive continuous improvement in aged care, and to develop options for proportional, risk-based assessment of performance against quality standards.

COTA also acknowledges that there are many requirements of aged care providers set out in the Aged Care Act 1997 (the Act) and other legislation and regulations, that the quality standards are not intended to duplicate or replace.

COTA notes that the implementation of new quality standards and assessment processes will require amendments to the Act and legislative instruments and the development of supporting materials such as an evidence guide, and will wish to consider all proposed changes and new documentation as these are developed.

COTA has considered the following matters of high importance to consumers when reviewing the draft standards:

Quality of life

Quality of life is of primary importance to older people. COTA recognises that attention has been paid to quality of life in the draft standards and generally the standards have been written in a way that acknowledges the importance of seeking each consumer’s perspective in defining quality of life.

It should also be acknowledged that quality of life for older people encompasses valuing and promoting the contributions they make to society, including the contribution they can make to service improvement.

Choice and control

The standards should assume an older person has managed their life for many years, drawing on a range of supports over time as a new or unknown challenge presents itself and that their experience of aged care should be no different. That is, the standards should presume capacity and reflect the older person driving their own life with more or less inputs from family, friends, and service providers (depending on their capacity, needs and preferences). Thus, the standards should include reference to how well the service enables this outcome.

Access to, and affordability of, services

COTA notes that access to, and affordability of, services are not addressed by the draft quality standards but these matters are covered in aged care legislation. However, to ensure that access to quality services and supports is not dependent on the ability to pay or subject to ‘cherry picking’ by providers, COTA considers that the organisation requirements for Standards 1 and 2 should be strengthened by requiring organisations to manage access, commencement and leaving a service in a transparent, fair and equal and responsive way. Organisations should be able to demonstrate that the ability to pay has no bearing on a consumer’s access to government-subsidised, quality-controlled services.

Conversely, consumers should be supported to understand the scope of aged care services and the parameters of aged care funding