[Opening visual of slide with text saying ‘Webinar’, ‘Inaugural Program Assurance Review of the Home Care Packages Program – Indirect and Care Management Charges’, ’29 August 2022’, ‘Australian Government with Crest (logo)’, ‘Department of Health and Aged Care’, ‘www.health.gov.au’]
[The visuals during this webinar are of each speaker presenting in turn via video, with reference to the content of a PowerPoint presentation being played on screen]
Good morning everybody. Welcome to our inaugural webinar on our Program Assurance Review. My name is Bianca Murcutt and I’ll be chairing our webinar this morning.
I’m just going to give our attendees a few more minutes because I can see more people are joining us. It’s lovely you’ve been able to take the time this morning to join us. We’re really excited to share our findings with you this morning.
Just give one more minute. I see more people joining us. How exciting. We’ve got almost 200 attendees with us so far which is great.
And we’ve cracked 204. That’s fantastic. Welcome to those of you who have just joined us. My name’s Bianca Murcutt. I’ll be chairing our webinar this morning and we’ll be commencing in just a few more moments.
Just waiting a little bit longer. And let us start. So good morning. My name is Bianca Murcutt. I’m a Director in the Program Assurance Branch in the Department of Health and Aged Care. You’re joining us today for a webinar on our Inaugural Program Assurance Review.
I want to acknowledge the traditional custodians of the lands on which I am on today, the Ngunnawal people, and pay my respects to their Elders past and present. And I invite you all to reflect on whose lands you’re on today as well as you join our webinar.
I also extend my respect to all Aboriginal and Torres Strait Islander people who are joining us today.
So this morning we have about an hour long webinar to run you through our Home Care Packages Program Assurance Review. We do have live captioning for our presentation and I notice that there’s a few issues with sound. We’ll be providing support to those people who are mentioning in the chat. Those of you who wish to use live captioning go to the chat function and the link should be there for you.
It will be available for about five minutes so if you do want to use that captioning please go in there now and follow that link.
So today we have three panellists from the Department of Health. We have Chamandeep Chehl who is the Assistant Secretary of the Program Assurance Branch. We also have Jarrod Bowd who is the Assistant Secretary Acting for Home Care and Assessments Branch. And we have Linda O’Rance who is the Assistant Director of the Program Assurance Branch.
I’m just going to pause for one moment to check if we have a major sound issue or if it’s just for some people. If my support team could just give me a signal about that.
Okay. For those people who don’t have sound it’s just getting you into the session. So that should be happening behind the scenes. Thank you for those of you in attendance who have told me they have sound. That’s great.
Also with us today we also have our Commission colleagues attending. So we have Cameron Bray who is the Director of Operational Policy and Support. We have Holly Harbour who is a policy officer also in that area. We have Graham Humphries from Home Services and Peter Edwards from the Financial and Prudential Residential Group. Thank you to our Commission colleagues for joining us today and they will be listening along to the session today and will provide any answers after the session to any questions you might have.
So we might jump in. There is a question and answer function in the webinar that you are on. So if you go down to your lower right hand side you can put a question in there. And we’ll be collecting questions throughout the webinar and we’ll try and answer them at the end. We may not get through to all of the questions but we’ll be collecting them and we’ll do our best to answer them after the webinar.
And just one last thing. The webinar will be recorded this morning as well so you will have a chance to listen again later.
So you can see on your screen now our agenda. We’ll be firstly going through our purpose and process of our Program Assurance Reviews. Then we’ll talk about the review of indirect and care management charges. We’ll talk about some future reviews. We’ll also talk about the community of practice that has just launched and then we’ll have our Q&As. So I’ll now hand over to Chamandeep Chehl who will take us through our first review. Thanks.
Thanks Bianca. And welcome everyone. Really nice to see over 300 people attending. Clearly program integrity matters a lot in relation to the Home Care Packages Program. So just briefly I look after what is now about a year old branch. Program Assurance Reviews are our main bread and butter but we also look at fraud management for the Home Care Packages Program. Today we’re going to talk you through the findings or at least I will talk you through the findings of our first review. The report is public. But we’ll get to it in a minute.
One thing I did want to kind of just emphasise is that my branch deliberately sits outside Jarrod’s program area and that division and that was a very deliberate decision to try and make the review activity as objective as possible.
Without further ado I’ll go to the next slide and get started.
Sorry. You might hear a thing of paper as my cue to lovely Raj who’s helping us flick through the slides. I’m not going to take I guess knowledge as given. So it may look like I’m reading off the slides a little bit but I do want to make sure everyone who’s listening in – because we’ll have a very diverse set of audience – what I’m saying does make sense. So I apologise for those who are very familiar with the program and why we’re doing program assurance reviews but it is important I guess to set the scene carefully.
Home Care Packages Program very, very significant program. There’s never enough packages. Everybody wants one because it is such a good program. $6.5 billion is the estimated expenditure and over 275,000 people expected to be in the program by the end of this year. So clearly there is an imperative to ensure that every dollar that is going towards the Home Care Packages Program is being spent for the purposes it has been approved by the people of Australia through the Parliament and legislature. And for those who are already receiving care it is important that they get absolute value for money from the Home Care Packages subsidy that they get from the Government.
What I really wanted to call out, partly because they may not be easy to read is that all our work under program assurance which is essentially going to enhancing program integrity of the Home Care Packages Program, these four risks kind of govern everything we do. So a line of sight directly to these risks. And not surprisingly the first one is about older Australians. So consumers, or as we like to call them, care recipients, if they can’t exercise adequate choice because a Home Care Package provider’s processes are unclear or there is insufficient transparency in the pricing information then that is a risk we’re interested in. And that was quite evident through the first review as I’ll take you through the key themes shortly.
Then for the taxpayers and the Government but also care recipients themselves, making sure that the program achieves value for money. So that’s another risk. If it is not achieving value for money we’d like to look into it. And then the last two unsurprisingly are about inappropriate, inadvertent or deliberate misuse of Home Care Package funds both by providers and care recipients.
So those are the four big risks. As you can tell they very much go to the overall investment of dollars in the program and the value that people are getting out of it. So it’s not the regulatory kind of function that our Commission colleagues who are with us today would fulfil. That said obviously we do work very closely with our Commission colleagues. But just to put it beyond doubt our job is not looking at compliance or regulation of the Home Care Packages Program. It’s very much about the use of the subsidy and the funding that the Government through this Department is giving. We’ll go to the next slide.
Now legislation does underpin our program. I forgot to mention that. That is because it is a very significant exercise for us and we know it’s an imposition on providers. So there is very clear legislative requirements on us but also impetus I guess for providers to participate when they get a legally binding notice from us.
Now I really think it is important to spend time to acknowledge the way providers participated in the first review. So we picked 100 providers. It was a very complex review. It was a first time for them and us. It is very natural to get defensive when a formal review of this kind that is legally binding is undertaken. But to their credit almost all providers were not defensive. Using my favourite phrase they kind of leaned into the process. They made senior officers available. They answered questions. There was a lot of back and forth during the draft report stage. So I really want to take this public platform to acknowledge all of those providers and their officers who engaged with us despite very challenging times including COVID.
I do also actually want to take the opportunity to thank our reference group members. So we have consumer and provider peaks on our reference group. We also have individual consumers as well as some providers. So I really want to thank them because they’ve been on a journey of a year or so with us. Obviously the nature of our work is that it is separate to them. So they didn’t have any decision making role but certainly a guide and a sounding board for us as we went through our journey.
And last but not the least – I can’t help myself – I really want to thank my team. It is truly almost blood, sweat and tears in terms of the nature of this first review. It was very complex. We couldn’t have picked a more complex one. It was very, very labour intensive. We’ll showcase that in a minute. And for a lot of people they were juggling many different balls at the same time including getting formal accredited training to be review officers. So I do want to thank them as well. Let’s go to the next slide.
So what did we do during the first review? We set ourselves out to find out the answers to four questions. And this is because for a long time even when we started which was in October ’21 there was a lot of public commentary and concern about high admin charges. I will explain in a minute when we go to the next slide why we’ve titled our review the way we have. It isn’t called a review admin charges, and I’ll explain that.
But the four questions basically we were trying to answer is what are providers charging for indirect and care management? Why are they charging these amounts? Their charging practices and methodologies, are they consistent with the program requirements? And for their own care recipients – because we picked a sample of care recipients for each provider – was it being applied consistently, their approach?
We looked at 100 providers as I mentioned and to our pleasant surprise five are volunteers. We looked at 16,000 documents. So my team had to pore manually through 16,000 documents which comprised things like the Home Care Agreements for the care recipients who were within our sample, invoices, pricing schedules, and a lot of information we also asked providers to provide us. I hope people can still see me. I’ve just seen a comment saying maybe they’ve lost me but as long as you can still hear me I think we’re okay. Can I get some indication maybe in the chat if people can still hear me?
Are we good to keep going? Yep. Can hear you. Okay. All right. We did 100 interviews. Thank you for all the thumbs up. We did 100 entry interviews. We did 80 exit interviews because they weren’t mandatory. So it was up to providers whether they wanted to participate. And unlike a lot of other audits or reviews we actually issued one report per provider. Because the intent behind this review is also to support continuous improvement of providers so it was very important to us to give them a detailed individual report that outlined what we found and where there might be actions for them or areas of improvement. And then there was one public summary report the key themes of which I’ll take you through shortly.
All right. So I find this really powerful so I did want to share it with everyone. This is providers’ own words. So these are providers who actually participated in our review. We didn’t solicit or ask for such feedback. This is of their own volition. All of it is awesome stuff but to me particularly the third one is of interest because I couldn’t have said it better myself if you asked me why should we do program assurance. I think ‘Happy to see value for money achieved’. Particularly ‘If everyone is transparent it will be easier for providers to justify pricing’. We also really appreciate that almost all providers said that they found the process to be very fair and my team to be respectful which is really important to us.
Let’s get into the report now. So this is the report. It’s been released by our Minister on 22nd of August. It is publicly available through the link. Even if you search I think through Google you happen to land on it. Before I go into the findings of the report just wanted to emphasise we really tried to walk in the shoes of the care recipients as well as providers and therefore as Jarrod knows – and I really want to acknowledge our program area’s cooperation on this – we really did call out where the program also needs to improve its guidance. So we’ve tried to make it as balanced a report as possible and as fair a report as possible.
The other thing I wanted to emphasise before we go into the findings is that there is a reason why it’s called indirect and care management charges. Even though the program’s been around a while it was interesting that there is still confusion in the public domain but also amongst certain providers as to the difference between what are admin charges and care management. So care management is a specific service type whereas indirect or admin charges can be things like package management charges or if a staff member is travelling to you without you or third party invoice surcharges. So where you want a provider of your choice if you’re a care recipient and your approved provider charges you something additional for the purposes of processing that invoice and facilitating that provider to be available to you, those are indirect charges. So care management is not an indirect charge hence it was very important for us to call that out separately. But euphemistically most people lump them in together but for us it was very important as a review team to get that right.
All right. Let’s look at the findings now. Next slide Raj.
So before I launch into this one just wanted to make it clear we’ve used here publicly sourced information. So this is pricing information available from our own My Aged Care website. This is pricing information the providers themselves have put in. It also is the most recent because our review took a while to do and it allows like for like comparison as much as that is possible. So all in all we thought this was a much better approach for us to take than rely on information that might have been provided to us directly by the providers and also not every service of the provider would have been included in our review.
So drawing on the My Aged Care information I think it is very fair to say that you can see a very, very vast variation in the charges for care management. So this is fully care managed by the provider. If you happen to be on a Level 4 – and I apologise you might not be able to see this clearly but it was important to put it all on the one slide but it is available in our report. If you’re on a Level 4 for example and you’re being fully care managed by your provider you could be paying nothing – and there were a few who claimed to be charging zero dollars – all the way up to $702 and everything in between. So median for example which is the darker green is kind of the mid‑point of the distribution. That’s about $315. If you look at it from the perspective of what is it as a share of the total subsidy – this is just care management remember. There is still package management to come and could be other indirect charges. So just for care management as part of your total subsidy, as a proportion of your total subsidy, on average you might be paying around 16% if you’re on a Level 4 but you could be one of those care recipients who could be paying zero all the way up to a third of your package just on care management charges.
Now the other thing about this is that you’ve got to be careful about a like for like comparison. So on My Aged Care there’s a minimum number or a guided number of hours that providers do put in. Some providers offer unlimited care management for the charge they are charging you. So on the face of it it may look higher than another provider but it’s basically no time limited. Others will offer you what they’ve said as a guide on our website. There are others who are for varying degrees in between. So it is quite important not to just go by the charge that you’re seeing. It’s really important as a care recipient to dig in and find out what are you going to get in return for whatever it is that the charge is and then make a judgment about is that value for money for yourself. Let’s go to the next one.
So now we’re looking at self-managed. So not all providers offer this but of those who do not surprisingly the charge is less than if they were fully managing you. But again if you look at Level 4 just to keep the comparison at the right level you could be paying anywhere from zero dollars again all the way to $464. And you can have varying degree of self-management versus support from the provider. And if you look at proportions again on average it could be 7% but you could be one of the care recipients who could be paying nothing all the way up to 23%. So you would either be fully managed or self-managed. So it’s important not to add those two up and look at this and go ‘Oh my God. How much would I be paying’ because you’d either be doing one or the other. Let’s go to the next one.
Now package management would be in addition to whether you’re doing self-managed or care managed. I’m not going through the definitions but in the report we have explained it, what the differences are between care managed, package managed, but in the interest of time I’m not doing it. There is also a definitions document that is on the website that gives you all the definitions that we relied on.
If you look at package management again sticking with Level 4 there is no zero dollars. The lowest price is $57 for package management for a Level 4 and it can go all the way up to $629. Now again for some providers package management can be all inclusive. You might not pay any other indirect charge. Everything will be picked up through package management. And yet for some other providers you will have package management plus some other indirect charges depending on your particular needs and we’ll go through that just in a minute. So again on average you might be paying about 10% of your total subsidy. And I’m assuming here obviously you might be aware that the subsidy levels, there’s means testing etcetera. But if you assume you’re getting the full subsidy, 10% of your total HCP subsidy for Level 4, but it can range all the way from just 3% to 31%. Raj can we go to the next slide?
So it is important just to remember with what we just went through that there could be other indirect charges on top for you to know what your total could be even if you’re using My Aged Care. Now pricing methodologies were immature. Just to be upfront the program does not have any requirement for a specific pricing methodology or the level of maturity but we thought from a review perspective it was quite important to understand what sits behind the pricing that providers come up with to charge care recipients for care management and indirect charges including package management. Because ultimately if you’ve got an inefficient pricing approach it will flow through to care recipients and could result in high admin charges. So overall we did find that only a few had what we would call – and look we’re no experts so we were going by what we were being given – from what we received from providers there were very few that looked like a really mature financial model. But it is important to remember that overall the split of not for profits versus profits in our review sample was about 75% to 25%. So 75% are not for profits and 25% were for profit. Let’s go to the next one.
All right. So this was the key concern for us not surprisingly because pricing transparency is absolutely essential if we want care recipients to exercise genuine choice and control. And for the Home Care Packages Program an absolute key tenet is consumer directed care. That’s the philosophy of the program and that requires an even sort of distribution of information, timely, correct, accurate, fulsome information available to both providers and care recipients if care recipients are able to exercise choice and vote with their feet. So it was an important test for us to see if we could find the level of pricing transparency that you would expect a care recipient to have.
We did find that many providers had pricing transparency issues. Now this could range from something quite significant to little but for an individual care recipient it could make a big difference. When dealing with older Australians we need to make sure that they can understand what is before them. So some examples of what we found is pricing schedules and what people were being charged and where was not consistent with the pricing schedule definitions. These definitions have been around for a while. Our team found them a very useful document. I would suggest everyone familiarise yourself, whoever is in the audience, whether you’re a provider, a care recipient, a carer for someone or just the general public interested. It is a publicly available document and it really outlines what should be charged under the various different definitions including for example for package management, staff travel, care management etcetera. It is really important that providers are across that and hold to it.
Pricing schedules must be attached to a Home Care Agreement. So Home Care Agreements are essentially a pricing contract between a care recipient and a provider. The Department does not have visibility of that. This time because of the review we had the ability to really look at this en masse but on a day to day basis the program area does not have access to these arrangements that are validly between the care recipient and the home care provider. So care recipients – and Linda my colleague will take us through this later – really need to understand the importance of Home Care Agreements and providers need to make sure that because these are legally binding documents they are correct and to be correct they do need the applicable pricing schedule attached.
Many providers did not list every charge that we came across on their pricing schedule in dollar amounts. And look this could be inadvertent. I’m not suggesting this is deliberate but it is something that we did find and it is really important that the pricing schedules are in dollar amounts and they have all the relevant charges applicable to that care recipient in that legally binding Home Care Agreement. We’ll go to the next slide.
Again we know pricing schedules have to be reviewed. If you don’t update it as a provider every 12 months that’s up to you but they have to be reviewed every 12 months. That wasn’t the case in all instances but for the majority it was the case. So there were only a few providers where we found this to be a concern. We also had a few providers lumping in care and package management together. As I mentioned at great length – and most providers are aware of this – they are very different charges. They’re defined very differently legally and they cannot be lumped together. We also had providers who stated not applicable or zero dollars for some charges. Now we’ve called this out in the report. There was no legal requirement not to be able to charge zero dollars but if you’re charging nothing for some services such as care management you still are obliged to deliver it whether you’re charging zero or not. A care recipient can’t be told that you can’t receive care management because it’s zero dollars. And if you are charging for it then it is better to be clear about it and call it out here rather than bundle it up with something else. Not applicable to us as a routine was you’re not offering that service. But there was some confusion around this and so we have suggested a bit of clarity around that one as well.
There was some discretionary waiving of charges but we couldn’t find any standard operating procedures in some instances. So it seemed to be up to the provider’s staff member to make sure that they were applying it consistently across various care recipients and obviously we wanted to be equitable. Although it was good that there was some waiving of charges. And while this was out of scope as public servants my review team and I are obliged to call out anything else we see that might be going to inadvertent misuse of Commonwealth funds or for some reason might not be appearing how it needs to be so we need to look into it. So we did see some annual increases in charges in a Home Care Agreement for example but it wasn’t evident to us whether there was clear agreement from the care recipient for that. Next slide.
So then we’ve got care and package management and other charges. So this was an interesting one. We found a pattern quite early that the majority of providers charge care management or package management as a percentage of the total home care subsidy. I’m not suggesting they’re lumping it together here and I’m not even suggesting that they’re listing it as a percent up on the pricing schedule. But the formula that they use or the method they use for determining the charges as a percentage. So it might be 15% of your total Home Care Package subsidy will go towards care management or 10% might go to package management.
What this means though as a care recipient is to be mindful that as you move from one level to another level package the total charge you’re paying will go up. Now we looked into this and asked providers for justification and for care management it was more justifiable that as care recipients move up you could have more complex needs for care and therefore care management effort increases and therefore it was justifiable to have more being paid for care management.
Package management less so given the nature of package management. So it is something to really look into and assure yourselves and for providers to make it very, very clear I think. If you are going to follow this formula I think it’s in your interest to make it very clear to the care recipients what they’re getting in return for a higher amount they’re paying. So it’s a mutual interest for both care recipients and providers to have more transparency and justification around that.
Also what is included as I said in care management or package management varies between providers. So again really important to look into it. And I’ve already covered before that if a provider is charging you zero even if you’re self-managed there are certain care management obligations on the provider and they must fulfil those.
It is important where you can care recipients do choose to vote with their feet and change providers if you’re not satisfied with the level of transparency and support you’re getting from your provider. But firstly it is important, because a lot of providers do want to do the right thing, to give the provider an opportunity to explain their perspective and rationale. Because providers’ pricing has to be based on their own contexts and challenges so it is good to ask them for explanations and understand the thinking behind why you’re being charged what you’re being charged. But if they’re still dissatisfied apart from complaints and other options you have if needed you can vote with your feet and move to a different provider where you have that option. Let’s go to the next one.
Third party surcharge was very interesting. There was some confusion around what this all means. Again we have provided some advice to the program area here to clarify requirements and definitions. But most providers who do charge this, they charge it as a percentage. So essentially you get an invoice from a third party provider of your preference. Your approved provider might charge you 10% on top of that for processing charges. It should be in dollar amounts. It also was evident that some providers didn’t have a cap. So when you’re charging a percent that is a particular concern because 10% of $100 versus 10% of a $1,000 invoice is a very different value proposition for a care recipient. So you might have signed up to okay I’m happy to pay 10% for third party surcharge but without a cap you could be up for a lot of charges.
Now to be fair most providers when we raised this with were of the view that a cap made sense and a lot of them moved to already make those changes while we were still in the review. So some of this could well be reflective of just lack of clarity of understanding rather than any deliberate practices on behalf of providers. Some did have a fixed hourly rate. So instead of a percentage they said okay we’ll charge you $60 an hour. Some providers will charge you an hour no matter what. Others had it in 15 minute increments. Again more value for money. I’m not making a call on this as the best value for money but relatively in the example we saw the more granular the pricing practice the fairer it can be for care recipients. So if I don’t go over my 15 minutes it’s better for me just to pay for 15 minutes than be docked a flat one hour for processing invoices. And as we’ve said in our report it doesn’t make sense that it would cost the same effort to process an invoice from the same third party provider again and again and again. Very few had a fixed dollar amount and partly the reasoning was we don’t know what the invoice is going to be therefore a percentage makes sense. And we’ve clarified the requirements in the report on what that looks like then in practice but I won’t spend time here going into that. Let’s keep going.
I’m trying to slow myself down. I’m naturally actually a very fast talker so I might be overcompensating and hogging more time than I’m meant to talk. Monthly statements. Again a very, very critical pricing transparency tool for care recipients. It is like your bank statement coming every month. You should look at it very, very carefully and Linda will take us through that later. But one of the interesting things we saw – so there is best practice guidance out there. It is not mandatory for providers but anecdotally what we’re hearing – in fact just recently I heard – is that some providers have actually adopted it and it is lending more to pricing transparency and this was from the words of care recipients. So that is really good.
What is legislatively binding though regardless of which template a provider uses – because not everyone’s system might support the best practice approach – every provider must give a level of visibility that is adequate for the care recipient. And so for example not listing the surcharge for third party goods and services in a monthly statement is not acceptable and some providers in fact did say to us they thought this was a new requirement and it isn’t. It’s been there always. And then there were some very generic catchall descriptions which frankly even we struggled to understand what the charge was for. And if we’re struggling then the care recipients would have. Rest assured one on one that feedback has been provided to those particular providers and all our providers who got their reports where there were actions they have until end September to get back to us to respond to the actions we required of them. Now these are again program assurance actions but where we don’t get what we need and there isn’t sufficient justification or engagement then it is something we need to look into, for example working closely with our Commission colleagues to see if we need to make any formal referrals, noting the Commission is independent to us. Let’s go to the next slide Raj.
I think I’m almost at the end of my session. So I won’t go through the third party ones because we’ve touched on them. But staff travel. Let’s look at that one. Lots of variation not only in the charges but the way it’s charged. So some charge per kilometre. So this is staff traveling without you as the care recipient. So it’s an indirect charge. Some charge per kilometre. Some charge per kilometre with a cap. So you will be up for a maximum of say $100 a trip, no more. I just literally made that figure up. It may absolutely not be relevant but it’s a cap and you know that’s the max amount for no matter where I live if you’re serviced by that provider.
Some did it only for example in the middle of remote regional Australia beyond a certain distance. They are big distances to travel so they had a per kilometre charge only if you were living really far away from where the provider services. And then there were some per trip charges. And the rate can be dependent on the service being delivered. If a nurse is travelling for example then the rate could be higher than if it’s a personal care worker. So again really look out for these sort of charges both as a provider as well as a care recipient to make sure these are transparent and justifiable. For most providers they were able to justify the charges for us when we asked but we were in the special position of being the review team where we were dedicatedly focusing on this and had the energy, effort and desire to get to the bottom of things. An older Australian may not be in the same situation so it is important to give as much transparency as possible.
Some other findings. There were a very, very small number – I don’t want to exaggerate – where the business administration costs were included in direct charges. Now this is not allowed. It should not be done so watch out for this as a provider inadvertently if you’re doing it. And it kind of goes to my point right at the start of really needing to understand your pricing and your cost drivers and where is the right place to recover the charges noting the pricing definitions.
A business decision for many providers is not to offer self-managed care. There is no obligation on them to do so. So it is just something we noticed as well so we thought we’ll call it out.
We have talked about charges being inconsistent. Again just emphasising it wasn’t only evident against the pricing schedule but also their Home Care Agreement or even their budget. So really watch out for that. These can be inadvertent errors, staff can turn over etcetera. But if you’re a home care recipient really important to look at your monthly statement and your Home Care Agreement and make sure the pricing schedule is all lining up unless you’ve agreed to a different charge in which case that should be documented somewhere so it’s very clear for you. At no point should you have to guess what am I meant to be charged.
Excluded items, contingency funds. Now these were out of scope for us. So what I mean by that is we didn’t do a review focused on these. But as I said before if we saw something we are meant to call it out. Excluded items, unfortunately we saw a lot of it and we weren’t even looking. And so for those providers we have engaged with them. I don’t mean to imply that in all cases it was unjustified. We have given providers the opportunity to tell us. But on the face of it there were excluded items. Now this is a mutual obligation both on providers and care recipients to be familiar with what is allowed and what isn’t allowed as program expenditure and to work together to make sure that inadvertently things aren’t purchased that are meant to be purchased from a general income for example.
Contingency funds. Very small number of providers we saw this as but basically we’ve got improved payment arrangements where there’s a whole different way of paying providers after the fact for services delivered. There is no holding of funds for rainy days with the provider now. The Commonwealth holds those funds for care recipients. So they are available to care recipients but this idea of contingency funds, it was appearing like a charge on a monthly statement but it wasn’t really a charge. And so even though it was mutually agreed with the care recipient it is something that isn’t okay and so we’ve called that out and we’ve also suggested the program area to make those requirements very clear just in case these are kind of legacy arrangements and providers haven’t realised or care recipients haven’t realised it’s no longer possible to approach things this way.
As I said before we really work in good faith with the program area to improve program guidance. And I do want to emphasise the review wasn’t all about trying to catch providers out. It was also about identifying some good practices. So just a couple of examples we found. There was the use of a payment platform for all invoicing and payments which means that care recipients could access real time statements which is really good. There were also time tracking tools which present evidence of charges applied for care management provided. So they were just two good examples of best practices. We have reported some in our report and then we’ve also captured them in the individual provider reports.
Let’s go to hopefully the conclusion. So I just want to leave you with this message of in our experience many, many providers are trying to or do want to do the right thing. It could be that the guidance was confusing. It could be that they’ve got legacy arrangements or their system doesn’t allow stuff etcetera, they have context, they are less or more efficient. Putting all that aside though it is important that the maximum amount of dollars are going to direct care and services for home care recipients. I think even providers won’t deny that.
Two clear key themes that were of concern. That pricing transparency absolutely has to improve because as I said before it goes to the heart of consumer directed care and empowering care recipients to do informed choice and control. And really those arrangements are between care recipients and providers and so it is really beholden on providers to support care recipients to achieve genuine consumer directed care. And then there was a wide variation in charges and what is delivered in return for those charges which makes a like for like comparison quite challenging I think unless there is more clarity of what is being charged and why and when.
Providers do need to cover legitimate costs. So we are not suggesting that there isn’t room for indirect or admin charges because we do want them to offer quality and safe care. But they do need to have a good handle on what the cost drivers are, what they need to recover and where otherwise it does flow on to having larger than required indirect charges.
I think ultimately the key message I’d leave everyone with is not because of regulation, not because of assurance reviews, but if we want a fairer home care packages market for all, not just care recipients but also providers, then it is in everyone’s mutual interest to make sure that the care recipients are more informed and empowered. And certainly we’ll do our part. So Linda will take you through the rest of the presentation which will hopefully showcase how we’re going to try and work with providers not just the ones we reviewed but the broader sector to try and support continuous improvement. And then there’s some future reviews. So it’s an ongoing program of assurance reviews so we will certainly be doing our part in supporting more informed and empowered care recipients through our work.
Thank you. That’s all from me. I’ll hand over to Linda now to take us through the next part of the presentation.
[Visual of slide with text saying ‘Enhancing consumer choice and control through Program Assurance Reviews’, ‘Linda O’Rance’, ‘Assistant Director’, ‘Program Assurance Branch’, ‘Australian Government with Crest (logo)’, ‘Department of Health and Aged Care’, ‘www.health.gov.au’]
Thank you Chamandeep. So as Chamandeep noted my name is Linda O’Rance and I am an Assistant Director with the Program Assurance Branch. My particular role is to lead our program assurance compliance function. And so we work with providers during the compliance phase following a review where they have the opportunity to address any corrective actions that are set out in their report. So I’ll be speaking today about enhancing consumer choice and control through the Program Assurance Review function.
And so essentially we are working very hard in the branch to use the information we’ve collected throughout the review to enhance choice and control by care recipients. And what we’ve found is that a really key finding was that price and transparency is absolutely imperative if care recipients are to be empowered to make value for money decisions about the services and care that are provided to them through their Home Care Package.
So as part of this the Department does publish national median prices for common home care services and care and package management charges. These are updated quarterly and they’re available on the Department’s resources page. A reference to this is in the summary report and later on in this presentation. And essentially we really found that there was a lack of consistency in how providers disclosed information about the HCP charges in care recipients’ Home Care Agreements and in other information such as pricing schedules that were published and provided to care recipients overall. This includes on the My Aged Care platform where a number of potential care recipients and existing care recipients have access to information about particular provider charges.
And we really found that when this information isn’t available or it’s available with insufficient detail care recipients just didn’t have the opportunity to make really informed decisions about which provider would give them optimal care and services to meet their particular needs and in a cost effective manner. And so from a care recipient perspective something that we would advise is if there’s ever any concerns or lack of clarity about the charges that you are being charged please do ask your provider to send you more detailed pricing information because for the most part that will be available and a provider really should be working with you to make sure that you have this precise information you need to make the decisions that you need to make.
So some of the findings have been touched on prior that really do affect a care recipient and one of those was the fact that some providers don’t charge for care management. And so something we really want to make sure that all care recipients in the program know is that even if a provider is charging zero dollars for care management they still need to provide that care management support to you as needed. And this also applies for self-managed care recipients. Next slide please Raj.
And so continuing on again and using our review information to enhance some consumer directed care we really want to make sure that care recipients know and are able to make a like for like comparison of charges. So charges aren’t always the same across providers. We do work in a market and so providers are able to choose which prices are most appropriate for the services they deliver and that means prices may differ for the same service from different providers.
We also noted that some providers do charge an all inclusive rate while others have additional charges which might be less obvious. So it’s very important to work with your provider to ensure you know exactly what different rates include.
We found quite considerable variation across providers for similar charges and the lack of clarity for care recipients probably was the primary concern with regards to that. And so we’d also encourage providers to work very carefully with the information that you have available and that you provide to care recipients to make sure they understand exactly what care and services they’re receiving and the total cost for those.
Another aspect of this is the monthly statements. And so for care recipients our advice would be that reviewing your statement on a regular basis and understanding exactly what’s set out in your statement is of absolute critical importance. We found during the review process sometimes it was quite difficult for review officers to understand the exact fees and charges that were set out in the monthly statement and the services that were being received. And so from a provider perspective we would really urge you to review your statements and make sure that they are as clear as possible because we felt that if a review officer struggled to understand a statement it would probably be quite difficult as well for a care recipient to really understand what their charges were.
And another thing to really specify both for a provider and from a care recipient perspective is that a monthly statement must list the full details of every charge so that a care recipient can determine if their funds are being used in the best way possible to meet their needs. And we did see that in a number of statements some charges were lumped together or not clearly differentiated. For example it may say service delivered where it could have been a personal care service or a gardening service for example and so it can be very difficult for a care recipient to determine exactly what they had received in the term of that month and what they were being charged for. Next slide please Raj.
So another aspect to be very aware of is as Chamandeep mentioned before – so I won’t go into this in too much detail – there may be third party sourcing and invoice processing charges charged by a provider and it’s very, very important to be aware of the charges and the implications. So as Chamandeep noted before a 10% surcharge on a $2 good or service may be quite reasonable because it comes to 20 cents. However that same surcharge of 10% if that was applied to perhaps a piece of equipment that came to $2,000 the surcharge itself would be $200 which may not be appropriate for the degree of support that went into organising that service for you. And as Chamandeep said some providers have commenced capping these charges which we found quite a beneficial outcome of the review.
And so with those charges we would really recommend that a care recipient determines whether they are being charged to have their preferred provider deliver goods or services. And when this does occur please check it before you sign your Home Care Agreement and then continue to review your monthly charges and then any subsequent changes to Care Agreements to make sure that your understanding of the charges remains correct. We’d also note that a Home Care Agreement is a pricing contract. That’s the charges that have been agreed between yourself and your provider and any amendments to those charges do need to be set out for you and agreed to by you. We’d also recommend that you take the time to understand how charges are calculated because at times it isn’t clear and it’s very important that a provider if asked take the time to explain the charges to you so you have a full understanding of what charges are and the implications they have on the delivery of your care and services.
Finally with staff travel we’d really note that do be aware of how a provider charges for staff travel. So that’s travel without you which may be to or from your home to deliver care to you. And if you’re ever in doubt please do ask your provider what travel charges are and how they’re calculated so you can understand specifically what that means for you and the price that then you’re being charged for delivery of your overall services.
Then finally just noting again with regards to care management – because this was a very, very important thing that came out of our review – we would really want to specify as the Department that care management is a very, very important aspect of Home Care Package service delivery for a large number of care recipients. And so as Chamandeep mentioned earlier it’s essential in ensuring that care recipients do receive safe and effective care that meets their individual and specific needs and their assessed needs. So for example care management is quite important for ensuring that services received by a particular recipient don’t overlap or duplicate other services that they’re receiving throughout their package or else through other services that are available because this isn’t cost effective and may reduce the overall funds available to meet other essential care needs.
And without sort of an oversight of care management that’s an aspect that can be lost and really does have the potential to lead to less choice and control by a care recipient and sub-optimal use of the funds that are available in their package.
Sorry. Next slide please Raj.
And next is just a brief discussion of excluded items under the HCP Program because this was an area where there was I think substantial confusion both from providers’ perspective and from a care recipient perspective. So providers are only allowed to provide and charge care recipients for goods and services that are approved under the HCP Program and there is information about included and excluded items in the HCP manual for providers and for care recipients and potential consumers as well. We are aware that there was substantial feedback about the fact that a lack of clarity in the advice provided was causing confusion for both care recipients and providers and we are currently working to improve that guidance and hope that it will be published shortly.
Thank you very much. And so we have a number of resources that are available both for providers and for care recipients. And we would really encourage care recipients and potential care recipients and their family members to do their best to understand how individual providers do charge for specific care and services because there will be different providers that are better suited to meet particular care recipients’ needs. The Department does have a pricing comparison tool which is available on My Aged Care that lets a potential consumer compare the prices for up to three different providers which can support you to identify the provider which is going to be most cost effective for the specific care and services that you need and you would like to arrange as part of your package.
The Department also publishes national median prices charged by providers on a quarterly basis which can then allow a care recipient or potential consumer to compare how their provider of interest compares to all providers operating in the home care space.
So we would also then note that specific support for care recipients and potential consumers is available through the Older Persons Advocacy Network and also through aged care system navigators. And so there are some links that will be available on these slides.
Sorry next slide please. And so as pricing transparency is absolutely integral to arranging to make sure that the care and services you provide are suitable to you we would recommend if you have any concerns or any questions to ask please do start by speaking to your provider and in particular your care manager would be an excellent place to start as they have existing oversight of your assessed needs and the services that you’re currently receiving. If you’re not able to resolve a concern directly with a care manager you are able to speak with someone within the provider to assist you with a complaint so please do ask to be referred. All providers are required to offer a free and supportive complaints management process which is available to every care recipient as required.
If a provider isn’t able to address your concerns through their standard complaints management process and they relate to the safety and quality of the care that you’re receiving you can contact the Aged Care Safety and Quality Commission for additional support.
And then finally if concerns relate to pricing information or fees and charges then you can contact the ACCC, the Australian Competition and Consumer Commission for again further information or support.
And sorry next slide please. So what are we doing with the findings of our first review? So there are a number of things that we’re doing immediately and then in the near future to address some of the findings of this review. So first of all we identified specific actions for providers to respond to and address which were set out in the final report that they received, the individual provider report. And our program assurance compliance team will follow that up. So I lead that program assurance compliance team and we will be working with providers and are already working with providers following the issue of those final reports throughout the first review.
We will be supporting providers through a range of actions which include education and support to understand program requirements, answer questions where possible or refer them on to the program area as appropriate, undertake further review and investigation where required and potential referral to the Aged Care Quality and Safety Commission if we are unable to address issues with providers and that’s the most appropriate course of action. Our intention is always to work with providers directly where possible to try and resolve any concerns upfront.
We also have a program assurance team who work with providers throughout the course of their review to provide the opportunity to address any corrective actions where possible throughout the review process. There are also a number of tools that are available on My Aged Care to compare the prices of services across providers which include an improved layout to display the provider costs, a quick cost checker tool and as I noted before a cost comparison indicator. The Department also has published a value for money considerations fact sheet for care recipients that draws from the review report. And the fact sheet also has further instructions on how to use the My Aged Care provider comparison tool and that fact sheet will be going up shortly on our Program Assurance web page.
And then of particular concern to both our providers and our care recipients, the Department is in the process of updating the HCP manuals for providers and consumers because we appreciate that a finding of the review was that a lack of clarity on both parts is really leading to some of the pricing transparency concerns that we noted and preventing some care recipients from making optimal choices about the care and services that they choose as part of their package and the value for money that it gives them.
We have established an online Home Care Package community of practice and a number of our providers are engaging in that already. It’s recently gone live. And we have two further reviews, one which is commencing at the moment over the next few days and another which we’ll really kick off in early September. So the second review overall that the Program Assurance Branch will be running is into unspent funds. And this review is determined to ensure the accuracy of the reported amount of the Commonwealth portion of unspent funds of selected providers and including selected care recipients.
The next review which will be the third review run through the Program Assurance Branch is looking specifically at pricing transparency on My Aged Care as this is one of the primary tools that care recipients and potential care recipients use to make decisions. And so this review is seeking to ensure that all providers are meeting the My Aged Care pricing transparency requirements, that the information displayed on My Aged Care is accurate and consistent with providers’ pricing schedules and is as straightforward and easy to understand as possible for care recipients.
Linda I’ll just jump in here. I note that we are 12 noon.
No. No. Not your fault. Not anyone’s fault. I’m just advising participants if you do want to stay we’re going to probably run for another 15 minutes. I know we’ve just got a little bit more. Linda’s going to talk about community practice and then we will try and answer a few of the questions. But if you need to hop off now absolutely understand. Thank you for your time. We are recording and we will have the recording available once we’re finished. Back to you Linda.
Thank you Bianca. This is the last slide so I’ll try and hurry myself up. And as I just noted we have established a community of practice which is designed to support providers to improve their own program understanding, share better practice between themselves and engage with the Department in a more straightforward manner. So HCP providers and provider and consumer peak bodies have been invited to join and a number have signed up to participate which is fantastic. And we would note that if you’re a provider or peak body representative and haven’t yet either signed up or received any information please do contact our provider education section because we would very much like to facilitate you participating in the community of practice.
And that’s the end of my slides so Bianca I’ll turn over to you to manage those questions.
In regards to the community of practice Linda there was a question about emails that people have been receiving asking them to confirm their participation. I think they have to click on a hyperlink. Just confirming yes that is from us. It’s not a phishing email. Is that correct Linda? Yes.
Yes. Great. I think you’re on mute. So if you do receive that email - - -
My apologies. I believe so. Yes. Thank you.
Excellent. So thank you so much Chamandeep and Linda for giving us that overview of the findings of the review. You can see there’s a lot of really interesting information there from the Department for care recipients and providers. So thank you to people who have been putting questions in to the question and answer function. We’ll probably only be able to do about three or four but we will try and respond to all the questions after our webinar concludes as well.
So first question, the key one that’s coming up from lots of people Jarrod is for you.
Q: When will the next Home Care Packages Manual be released?
Everyone’s so excited to see it.
Thank you Bianca. Yeah. As you mentioned the Department’s well aware through different forums at this stage obviously that providers and care recipients are wanting greater clarity, greater certainty on the inclusions and exclusions for the program. I guess the Department has been – I guess through the consultation process with support at home, also through this report, the first Program Assurance Review, a lot of different things have come up through both in terms of items that care recipients are seeking to have included or they’ve been unsure whether or not it should be included or excluded. So the Department’s I guess taken the opportunity to consolidate all rather than updating their manual on a piecemeal basis. So in terms of timing I guess at this stage I’m confident that we’d have updated clarity and guidance with the manual etcetera within the next couple of months. I know people are probably looking for a shorter deadline than that but at this stage I guess I can only confirm within the next couple of months we hope to have the updated manual published. So thank you.
Thanks Jarrod. I’ll pass over to you Chamandeep now. A few questions have come through. People are particularly interested about why we didn’t name the participating providers in the review. Could you talk on that for us?
Sure. And I’ll try to be short this time around. Legally we can. So we do reserve the right essentially to be able to name providers going forward where the public benefit outweighs the risk of doing so. Because we obviously have to preserve commercial in confidence nature of our reviews and the sensitive nature. But for this one it was the inaugural review. Most providers have shifted behaviour and we have issued individual reports where they have the opportunity to come back and tell us if they’re going to remedy something or not and if they don’t then we do have the option obviously to work closely with the Commission as well.
So on balance this time around we didn’t do it but it is something that is available to us in future if needed.
Thanks Chamandeep. Another question for you Jarrod. Chamandeep talked about the better practice monthly statement and there was a question clarifying whether the use of that template was mandatory because there was suggestion perhaps that it is becoming mandatory later this year.
Thanks Bianca. Can confirm definitely not mandatory the template in itself. Obviously providers even through the review having looked at the 100 providers, a lot of different monthly statements are currently being employed and utilised by providers and care recipients. So there’s a bit of work I guess, further work that the Department needs to work through in terms of with monthly statements and whether or not what kind of format they’ll look like in the future. But can confirm I guess the mandatory part is from September that unspent funds in the monthly statement themselves will need to be split out. So that’s the big change in September. But the Department is working through still some options I guess with the monthly statements for future consideration of implementing and introducing some changes. But in short can confirm the mandatory statement won’t be a mandatory one statement that will be utilised across the sector from September.
Fantastic. Thanks Jarrod. And then Chamandeep I think if we just have one more question. There was a question earlier in the session when we were comparing care management. A person noted did we consider care management hours, because obviously if you’ve got more care management hours then you would expect a higher cost of care management charges. Can you talk on that?
Yes. I mean I’d have to go to the details of the individual report. So I’m going by memory here but as a general principle yes we absolutely looked at either what that provider was offering based on whatever was said on My Aged Care or where the provider had told us themselves. So we certainly did look at it from that perspective but it is not something we’ve really called out obviously in the report. But for individual providers we have engaged with them where we had some questions around that.
Fantastic. Thank you so much. Well we might finish off our session there. So again a big thank you to our presenters and thank you to all of you for attending today. If you have any questions after the session we have taken a record of all the questions that have been put through in the Q&A but if you have questions after the session please send them through to us. You’ll see on the screen there it’s HCPProviderEducation@health.gov.au. And we’ve also given the Aged Care Fraud email address there if you have any questions or any information you wish to share with us about that. And if you have any questions about Program Assurance Reviews including those future reviews we talked about it’s email@example.com.
Thank you so much and enjoy the rest of your day.
[Closing visual of slide with text saying ‘HCP Program Assurance Reviews’, ‘Thank you for your participation’, ‘If you have any questions after the session, please send them to HCPProviderEducation@health.gov.au’, ‘for Aged Care Fraud please contact firstname.lastname@example.org’, ‘for Program Assurance Reviews please contact email@example.com’]
[End of Transcript]
- Bianca Murcutt Director, Program Assurance Branch
- Chamandeep Chehl, Assistant Secretary, Program Assurance Branch
- Linda O’Rance, Assistant Director, Program Assurance Branch
- Jarrod Bowd, Director, Home Care Assessment Branch