READING TIME · 6 MIN

Aged Care Act: 200 days in — emerging challenges and opportunities

At the SSD Connect Alliance's 200 Days In forum, CHSP and Support at Home-funded aged care providers came together to reflect on how implementation of the Aged Care Act 2024 is progressing.

The discussion built on issues raised at our 100 Days In forum. Organisations continue to adapt their systems, policies and practices, with growing attention to audit readiness, administrative sustainability and practical ways to streamline implementation.

Participants shared practical examples, emerging opportunities and areas where clearer guidance or a more consistent approach could ease pressure on providers and their teams.

Below is a summary of the key themes from the forum discussions.

1. Service agreements, care and service plans

Service agreements continue to create a significant administrative burden for providers.

Participants reported that different templates are being used across providers. This can mean older people need to sign multiple agreements, while organisations spend considerable time following them up.

Participants also noted a lack of government communication to older people about why the agreements have been introduced.

Suggested improvements

Participants supported:

• one service agreement signed once when an older person engages with the aged care system
• a single agreement template used by all service providers
• a standardised template developed by the government.

2. Using AI to streamline processes

Participants discussed how AI is improving efficiency across clinical and administrative processes. Participants shared examples of how AI is already being used to:

• identify keywords in clinical notes that could trigger clinical reviews
• support wound analysis
• automate service agreements during onboarding
• connect a caller's phone number with their client record so staff can better assist the caller and arrange interpreters where needed.

Participants also discussed scoping recommended AI platforms and the importance of acknowledging, promoting and supporting AI use.

The main challenges identified were:

• cost
• limited knowledge and understanding
• the need to continue encouraging and supporting AI adoption.

Suggested improvement

Participants called for practical training sessions on AI.

3. Associated providers

Associated provider arrangements remain complex and resource-intensive.

Participants reported that requirements can differ between providers. This includes police check requirements, requests for hard-copy documents and audit requirements.

Legal review and other legal considerations are often needed. Organisations must also manage individual agreements with multiple providers, even when only a small number of older people use a particular provider.

Participants noted that contract administration takes considerable time and is often unfunded. It can also be difficult to identify the correct contact within provider organisations.

There was concern that the administrative burden placed on associated providers may make service delivery unsustainable across the sector.

Participants also reported using the Associated Provider Audit Tool. This tool is part of the Associated Providers Toolkit, developed by the SSD Connect Alliance and Victorian SSD partners with Enkindle Consulting.

Emerging opportunities

Participants identified opportunities to:

• develop in-house multidisciplinary teams and strengthen internal capability
• reduce reliance on external associated providers where appropriate
• establish dedicated contract administrator roles
• provide greater support for contract and compliance management.

Suggested improvements

Participants called for:

• less duplication across provider agreements
• more consistent provider requirements where possible
• greater transparency between CHSP and Support at Home arrangements
• support to build strategic provider partnerships
• reduced unfunded administrative work
• a stronger focus on client outcomes rather than compliance processes.

4. Preparing for audits and renewing registration

Preparing for audits and registration renewal continues to place pressure on organisations, their systems and their workforce.

Organisational change

Participants reported changes to organisational structures and management arrangements, alongside the work required to translate the new Standards into operational practice.

Organisations are also managing increased documentation requirements and ongoing expectations for continuous improvement.

Workforce capacity

Maintaining up-to-date continuous improvement plans takes time and resources.

Participants also highlighted the challenge of finding time for:

• staff training
• clinical training
• organisational development
• service improvement activities.

Service delivery staff also need opportunities to contribute to compliance activities.

Change fatigue

Participants described growing change fatigue as organisations work across:

• HR requirements
• increased documentation and evidence collection
• multiple accreditation streams
• competing priorities.

Regulatory processes

Participants raised issues related to the submission of Commission forms and called for greater clarity about:

• service types
• client examples expected in the Evidence Collection Tool
• expected evidence standards
• audit evidence collection tools and the level of detail required.

Across the discussions, participants recognised that preparing for registration and audits requires:

• significant investment in documentation, governance and training
• strong clinical governance and continuous improvement systems
• clear guidance from regulators about evidence expectations
• practical tools, templates and examples
• a balance between meeting compliance obligations and maintaining client-focused service delivery.

Audit readiness

Participants raised important questions about audit preparation, including:

• whether gathering certifications and evidence leads to a compliance file rather than genuine practice improvement
• how evidence should be organised and managed
• what level of evidence auditors require.

Suggested approaches included:

• explaining audit expectations to staff through practical examples
• using the Commission's conversation cards to strengthen workforce understanding of the standards
• completing risk assessments every two months or quarterly to identify gaps and mitigation strategies
• recording identified risks and actions in a risk register or quality improvement plan.

Resourcing

Participants suggested developing evidence libraries linked directly to the standards.

They also highlighted the impact of compliance requirements on operational service delivery.

Audit expectations

Participants called for:

• greater clarity about auditor expectations
• more guidance on what constitutes sufficient evidence
• a better understanding of how to demonstrate compliance without creating unnecessary administrative burden.

5. Responsible persons

Participants raised questions about access to the Government Provider Management System (GPMS) for CHSP staff.

There was also uncertainty about which reporting requirements sit with responsible persons.

6. Managing complaints, feedback and whistleblowers

Participants reported that whistleblower disclosure processes have not yet been effectively tested.

They also identified a need to:

• assess risk levels
• establish clear escalation pathways
• implement clear reporting and feedback mechanisms to ensure matters are appropriately managed and closed.

Suggested improvements

Participants called for:

• Standards documentation to be updated to reflect legislative changes
• additional guidance on documentation and implementation
• clear reporting pathways or decision trees
• clarification about which matters should be reported to responsible persons
• clearer reporting obligations and escalation pathways.

7. Workforce psychosocial safety

Participants reported an increase in incidents involving members of the public.

Organisations are responding by:

• creating new roles to better support staff
• involving HR more closely
• giving staff permission to end a call or service when needed
• putting clear policies and procedures in place.

Suggested improvement

Participants identified professional boundaries training as a priority for further support.