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04 Dec 2018

The AMA was represented by Dr Kean-Seng Lim and Dr Simon Torvaldsen at the House of Representatives Standing Committee on Health, Aged Care and Sport to discuss the AMA’s submission on the Aged Care Amendment (Staffing Ratio Disclosure) Bill 2018.

The Bill aims to obligate residential aged care providers to publicly publish their staffing ratios to improve transparency and consumer choice. 

The pair appeared as witnesses to the inquiry, with their evidence being considered by the Committee.

Dr Torvaldsen pointed out that while said it was a necessary requirement to have adequate staff at residential aged care facilities (RACF), it was not sufficient alone.

“In other words, if you don't have adequate staff, it is impossible to deliver good quality care, but having adequate staff alone—particularly if they’re not well trained or the corporate culture’s not good or they’re staff who just don’t want to be there—doesnt guarantee good quality care,” he said.

“So, it’s only the first step in the journey. But, to illustrate the point, I’ve been talking to the nurses and the staff who work in the facilities that I visit. Earlier in the week, when I spoke to one of the nurses and said that I was going to have to change my normal time of visiting on a Friday morning because I was giving evidence to this Committee and we were looking at what could be done to improve staffing ratios, she burst into tears and she thanked me for standing up for what was so desperately needed. And this comes from the people who are working there. They want to give good care.”

On palliative care, Dr Torvaldsen said it should be regarded as an integral function of aged-care facilities.

“It’s a fundamental part of what we do and what we should be doing,” he said.

“I think that that is most properly addressed by looking at the training and the skills mix, and just emphasises the fact that we were talking about earlier: that ratios alone without proper skills and adequate training don’t give the whole picture. I guess the difficulty is that we have to use some kind of instrument to adjust for case mix and needs and so forth. If someone has a better suggestion than ACFI (Aged Care Funding Instrument) [or ACAT – Aged Care Assessment Team], then we would be only too happy to hear it and to discuss it.”

Dr Lim said the AMA recognised that measuring the staff numbers in RACFs was just one element of achieving and maintaining high standards of care.

“It comes under this question about what the purpose of measurement is,” Dr Lim said.

“If the purpose of measurement in this case is the combination of accountability and transparency, which are important from a consumer perspective, we do also need to consider the element of improvement.

“The measure which has been suggested here is the staffing ratio. If we follow the Donabedian model of quality improvement, it’s actually a structure measurement. There are three elements to measuring: structure, process and outcomes. If you choose just one of three only, the problem is that we are always going to end up having, well, perverse outcomes.

“It’s useful to consider this as a foundational element but also useful to consider that this is probably not going to be the final thing, and it’s not the complete measurement but just part of it. For there to be informed accountability and transparency from a consumer perspective, this needs to feed into process and outcomes measurements as well.”

The Donabedian model is a conceptual model that provides a framework for examining health services and evaluating quality of health care.

The AMA’s submission to the Inquiry says that while residents living in RACFs typically have high care needs, the level of care, and therefore staff to resident ratios, vary between RACFs.

For example, a RACF that has a lower staff to resident ratio and few nursing staff may still provide high quality care if most of the residents have low care needs.

Conversely, a facility may offer a relatively higher resident to staff ratio with few nursing staff, but the quality of care is poor because the needs mix of the residents is consistently high. The most widely understood expression of level of care per resident is the ACAT assessment.

Similarly, contextual data could include the level of need of residents in peak periods of the day. For example, mornings are particularly busy as staff must get residents out of bed, bathe or shower them, feed them, and assist in toileting. Conversely, residents require less assistance while asleep and staffing levels may reduce at this time.

“The Government should also provide information on the roles of the different staff categories,” the submission states.

“This includes information on what the different types and levels of nurses entails. This would ensure consumers are able to make an informed choice. The AMA is presuming that the staffing ratios and subsequent information will be published on My Aged Care, as this is where consumers will look to compare RACFs.

“There should be more information on the roles and mix of allied health professionals. Many RACFs do not employ allied health professionals but instead engage with them externally, and this should be reflected in the reporting mechanisms. Allied health professionals are an essential part of the aged care workforce and their availability is crucial to resident care. The different types of allied health professionals should also be categorised, as older people may seek certain types of allied health support when choosing their RACF.

“The AMA is concerned that publishing staffing ratios alone may potentially result in setting a ‘poor standard’ of staffing as the commonly accepted ‘minimum’. Whereas, a regulated minimum staff ratio, developed in consultation with the medical profession and other key stakeholders, would prevent this. Staffing ratios need not stifle innovation, but rather can lay the foundation on which better quality care standards can be built. A regulated minimum will, in our strong opinion, still allow RACFs to find innovative ways to care for their residents, through a different mix of staff, above the minimum ‘safety net’ of staff required.”


The AMA’s full submission to the inquiry can be found at:

Published: 04 Dec 2018