ACCPA Issues Paper released

Published 4 August 2023

Following AHPA’s invited participation at an Aged Care Financial Sustainability Summit convened by the Aged and Community Care Providers Association (ACCPA), we provided a submission to an ACCPA Issues Paper.

The Issues Paper summarises aged care stakeholder views on what should be included in designing a new funding model for aged care, and has been provided to Minister Wells and the Aged Care Taskforce.

AHPA is pleased to see these points in the Paper:

  • the Federal Government should continue to be the primary funder of care services – as they are for Australians throughout their lives through the NDIS, Medicare and the public health system.
  • People should not be treated differently simply because they are over the age of 65, regardless of whether they are still living in the community or in a residential aged care facility.
  • any consumer co-contributions to aged care funding should only be for accommodation and living expenses, and not personal care.

AHPA also supports the Paper’s 10 Principles that emerged from the Summit, that the new system should be:

  • independent and person-centred
  • efficient
  • transparent and specific
  • equitable
  • means-tested
  • flexibly designed for First Nations aged care
  • universal
  • future-focused
  • guaranteed
  • inter-generationally fair


Reablement and allied health

However, we believe that the Principles should put a greater emphasis on reablement. In its Final Report, the Royal Commission into Aged Care Quality and Safety concluded that reablement is critical to older people’s physical and mental health and wellbeing and should be a central focus of aged care, whether the older person is living at home or in residential care.

Due to incidents such as falls, or simply because of the ageing process, older people can suffer or be at risk of experiencing a loss of capacity which can impact on their quality of life. Reablement is about preventing such losses where possible, and rehabilitating and restoring, or at least preserving as much as possible, older people’s capacities.

Allied health practitioners provide clinical care with a focus on prevention of functional decline, along with early intervention and treatment to support a person’s function and quality of life. The Royal Commission concluded that allied health service provision is essential for reablement, but that allied health services are underused and undervalued across the aged care system. The Commissioners found that this significant under-provision of allied health care produces morbidity, mortality and negative quality of life impacts, including those associated with dementia, mental health, malnutrition and falls.

Accordingly, the Royal Commission concluded that allied health should be treated as a fundamental element of the aged care system.

The under-emphasis in the Issues Paper risks repeating how reablement has been side-lined in Government implementation of the Royal Commission recommendations – with dire consequences for the place of allied health in any new system.

Data from the Department of Health and Aged Care shows that the median total allied health minutes provided per resident per day is now a paltry 4.6 – significantly less than the 8 minutes criticised by the Royal Commission, and at best, around a quarter of the 22 minutes recommended.

The Royal Commission recommended that residential aged care include a level of allied health care appropriate to each person’s needs, but unlike minutes for nursing and personal care, there is no clear and enforced benchmark for allied health care provision, and no specifically allocated funding.

David Tune’s recent Report of the Independent Capability Review of the Aged Care Quality and Safety Commission also refers to concerns about allied health needs not being explicitly assessed as part of the Aged care Quality Standards,’ resulting in the risk of consumers being left with unmet needs even while providers may be found to have met the Standards’ (p62).

An effective aged care system must also be able to demonstrate that people are receiving allied health services according to assessment of their clinical needs, and that care is being appropriately planned, delivered and coordinated. But Australia still lacks a nationally consistent process to ensure that the allied health needs of individual aged care residents are actually met.

If these major flaws in the aged care system and the resulting gross under-provision of allied health services are not addressed, there will not be the key focus on reablement and the associated quality of life benefits for older people that the Royal Commission supported.

Funding for health services in aged care

AHPA welcomes the Issue Paper’s view that healthcare should not be a two-tiered system with access to some healthcare only being available if the older person can afford to pay ‘extra’.

However, we think the Paper should have addressed the fact that just bringing older people up to the standard of everyone else who has access to healthcare is not enough, because there are growing inequities, such as gap fees under Medicare, that end up restricting access to disadvantaged consumers. AHPA believes that healthcare, including needs-based allied health in aged care, should not be subsidised by the consumer but should be funded out of general revenue.

It is also imperative for the Government to heed the Royal Commission and ensure that allied health services for people receiving aged care are usually provided by aged care providers (Recommendation 69, accepted by the previous Commonwealth Government). Allied health to support reablement should be a cornerstone of a high quality aged care system, and not hived off to the health system.