Welcome to the Star Ratings webinar. My name is Joshua Maldon, Assistant Secretary of the Choice and Transparency Branch of the Quality Assurance Division of the Department of Health and Aged Care. I’m joined here today by my colleagues. I’ve got Emma Cook here who’s the Director of the Star Ratings Section. Next to Emma Cook we have Emma Jobson who’s the Executive Director of Regulatory Policy and Intelligence at the Aged Care Quality and Safety Commission. And we’re also joined online by Mark Richardson, Assistant Secretary of the Residential Care Funding and Reform Branch.
I want to begin today by acknowledging the Ngunnawal and the Ngambri people, traditional custodians of the land on which this webinar is broadcast from today. And I want to pay my respects to their Elders past, present and emerging. I also want to extend that respect to Aboriginal and Torres Strait Islander peoples here today.
So I want to start off by saying a big thank you for taking the time to join us and hear about the purpose, the design and the implementation of Star Ratings for residential aged care. I want to thank all of you who’ve fed into this process through the conversations, the surveys, the submissions, those of you who rapped my mobile phone out. I also want to thank my team who have put their expertise, their heart and soul into this initiative. I also want to thank our colleagues at the Commission feeding into this process and working with us really iteratively. And I also want to thank our consortium partners, the University of Queensland, PwC and the Aged Care Industry IT Council.
So today we’re going to be taking you through the key information about Star Ratings, so in particular information about the overall Star Rating and rules for the four sub-categories, the reporting requirements, how Star Ratings will be displayed on My Aged Care, supporting communications and resources and what the next steps are.
So whilst this webinar is intended primarily for a provider audience we welcome older Australians and their representatives and we’re going to be outlaying the upcoming communications and resources that will help you understand and benefit from star ratings. I want to encourage you to post your questions in the chat as we go through the webinar. We will have a substantial question and answer session at the end.
[Visual of slide with text saying ‘Section 1’, ‘Introduction’]
So I now want to provide a brief introduction to star ratings including its origin, background and a plan for launch and delivery. So just to quickly reorientate ourselves with the Royal Commission. Star Ratings was at the heart of the Royal Commission into Aged Care Quality and Safety which highlighted that there is currently a lack of measurement and transparency in the system and that we need to have a philosophical shift to place the voices of older Australians at the centre of the system. So in response it recommended a comprehensive approach to quality management including indicators to measure quality, benchmarking for continuous improvement and a star rating system for comparing the performance of providers.
The Royal Commission did level criticism at all aged care system actors including providers and those of us who work in Government roles and it diminished community confidence in the system. And we are all here today because we believe and are committed to improving aged care quality and in rebuilding public confidence in the system. Star Ratings is something that needs to be embraced by all of us particularly aged care providers if we are truly to switch the community’s perception of aged care. So if we move through the slides…
As you will be aware Star Ratings are expected to be available on My Aged Care in December 2022. A provider preview of ratings will be available for at least one week prior to publication and we will talk about some detail around that later on in the webinar. If we can give providers more time we will, however, I am unable to commit to those specific dates right now. We’re in the process of bringing in data from multiple source systems and combining these in algorithms in our IT environment and we are testing and re-testing. What I can commit to you is that we will continue to communicate with you regularly and we will let you know when we have certainty about those dates. Thank you. Next slide.
So Star Ratings will deliver a range of benefits for older Australians and their representatives, providers and Government. Older Australians and their representatives will be able to easily compare the quality of residential aged care homes to easily make choices on care options. Providers will be able to use nationally consistent quality measures to monitor, compare and improve services and deliver high quality care to older Australians. And Star Ratings will provide Government with transparent information about the quality of aged care at a system level. And again for all of us if we engage in it, own it, we can flip the switch on community confidence in aged care.
So I’d now like to hand over to my colleague Emma Cook, or Emma C, to cover the development of star ratings and the fundamental design. Thanks Emma.
Thanks very much Josh and thanks again to everyone joining us. As Josh has outlined I’ll now walk through the star ratings scale, calculations and reporting.
[Visual of slide with text saying ‘Section 2’, ‘Star Ratings’]
So on the next slide you’ll see that Star Ratings will be published from December 2022 for all aged care homes in Australia, publishing an overall Star Rating as well as four sub-category ratings across key areas. These areas include Residents’ Experience, Compliance, Staffing and Quality Measures. Each of the sub-category ratings contributes a different amount to the overall Star Rating. These ratings are based on stakeholder feedback regarding the importance and maturity of each of these data sources.
Residents’ Experience is based on interviews with aged care residents regarding their experience of an aged care home and it contributes 33% to the overall rating. Compliance is based on the decisions of non-compliance by the Aged Care Quality and Safety Commission and the Aged Care Quality Standards. Compliance makes up 30% of the overall star rating. Staffing relates to the amount of care received from a registered nurse, enrolled nurse or personal care worker relative to each service’s individualised target. Staffing makes up 22% of the overall Star Rating. Quality measures: Quality measures measure crucial areas of care including falls and major injury, unplanned weight loss, pressure injuries, medication management and physical restraint and contributes 15% to the overall Star Rating.
Star Ratings will be based on a one to five star scale with the scales representing a one star at significant improvement needed, a two star indicating improvement is needed, three star indicating acceptable quality of care, a four star rating indicating a good quality of care and a five star rating for an excellent quality of care.
Now that we’ve covered the overall construct and labelling I’ll move into the calculations starting with the overall Star Ratings. So as you can see on the screen all four sub-categories are required to calculate an overall Star Rating. Without data or information for each of the four sub-categories I’ve walked through an overall star rating cannot be produced for a service. The score of each sub-category is calculated and then based on the overall rating or contribution to the total score as I’ve just spoken through. These sub-category scores are summed to produce a total out of five and then a star rating is allocated based on the thresholds shown under number two on the screen.
You will note at point three that if a Compliance rating score is one or two stars this caps the overall Star Rating to the same score as has been awarded for the Compliance rating category. And finally the overall Star Rating is produced.
So then jumping in to each of the sub-categories and I’m going to walk through each of those and how we’ve come to the values that feed in to that overall calculation, starting with the category that has the greatest contribution to the overall star rating which is the Residents’ Rxperience. So Residents’ Experience uses a score generated from Consumer Experience Interviews. These interviews are conducted by a third party annually. So it’s not a Department or a Commission workforce. It’s a third party who comes in to anonymously interview and understand the experiences of residents at an aged care home.
The interviews use a simple set of 12 questions with four possible responses to each. You can see these listed on the screen and these responses are ‘never’, ‘some of the time’, ‘most of the time’ or ‘always’. One through to four points is then allocated based on the least to most positive responses respectively. The point value of the response is multiplied by the percentage of care recipients or older Australians at the service that have that same response. These points are then summed to create a total score.
And using the thresholds that are shown again on the screen under item three a star rating is allocated to each aged care home based on the experience of their residents. If an aged care home refuses to allow older Australians to participate in the survey they will receive a one star rating for that sub-category I should say.
Now moving through to the next sub-category we have Compliance. So decisions of non‑compliance by the Aged Care Quality and Safety Commission informs the Compliance Rating and as such no reporting is required by the aged care home, the same as the consumer experience component that I’ve just spoken through which also is not reported by aged care homes themselves. A home receives a star rating of one through to five stars based on decisions of non-compliance or a period without. A one star rating is applied where a service has an active sanction, a Notice to Agree or a Notice of Requirement to Agree, as well as an infringement. So you can see those listed up on the screen.
Two stars is applied where a service has an active Notice to Remedy or Compliance Notice. Three stars is allocated to a service with no current non-compliance or with directions to support their improvement.
Four stars is allocated where a service has had no non-compliance issues present for at least one year and five stars are awarded if an aged care home has been compliant for three years and has met all criteria in a three yearly accreditation review.
As mentioned for the overall Star Rating calculation it’s important to note that a one or two star Compliance Rating will cap that overall rating to be the same as this sub-category.
Moving through to the Staffing Rating.
Care minutes for the Staffing Rating are reported by residential aged care homes in the Quarterly Financial Report. The most recent Quarterly Financial Report data is being used for the December 2022 Star Ratings calculations. Each service has a care minute target based on the AN‑ACC case mix of their residents.
On average this is 200 minutes total care time from a registered nurse, enrolled nurse or personal care worker and 40 minutes of registered nurse time.
The Staffing Rating measures the direct care minutes delivered to each resident in relation to their AN-ACC target.
Moving to the next slide you’ll see how then the star ratings are applied. So care minutes are converted into the Staffing Rating based on the table shown which is basically the degree to which the home meets or exceeds their target which is based on the needs of their care recipient population.
And moving through to the final sub-category, Quality Measures.
This is, and I need to warn, probably the most complex of the sub-categories. Please do be reassured that there are further details of these available both in a provider manual on the Department’s website as well as the summary report and a range of materials that are or will soon be available to support the star ratings.
So walking through these, every quarter data for five quality indicators are reported through the National Aged Care Mandatory Quality Indicator Program. Quality indicator data that will be used in the star ratings was due on the 21st of October. Quality indicators are transformed from those reported for the QI program for use in the star ratings. So this includes exclusion of stage one pressure injuries, consecutive unplanned weight loss and inverting the antipsychotic medication management quality indicator. So some minor changes to make them more appropriate to publish through the star ratings.
Three quality indicators are then risk adjusted to allow fair comparison between aged care homes. These include pressure injuries, unplanned weight loss and falls and major injury.
Other adjustments are made in the transformation of the quality indicators that I’ve just mentioned. Data for each of the quality indicators is then divided up into five equal groups of 20%. So if we order everyone in terms of performance the lowest 20 would be put into one group, the next 20 put into the next group and so on. So there’s five groups of 20%.
If there’s more than one indicator in the category then we weight the measures based on their severity. So for pressure injuries for example you can see on the screen that the worse the pressure injuries the higher the weighting is to acknowledge that difference in severity.
The scores are then awarded a one through to five point score for each domain, so for each of the five quality indicator domains across those crucial areas of care that I’ve mentioned. Those are summed and you’ll see on the next slide to a total score out of 25 and this is used against the thresholds that you can see or cut off points that you can see there to award a one through to five star rating for the quality measures rating.
So that completes the walkthrough of the labels, calculation and reporting and I’ll now hand over to Josh to walk through some key information you’ll need to know for the launch of star ratings.
[Visual of slide with text saying ‘Section 3’, ‘Key information’]
Thanks Emma. So as part of that – and you’ve gone through the complex piece, the technically dense piece if you like – I thought it might be helpful just to take people along the pottered journey of the development of star ratings to let you know how we got to the situation as Emma’s just described.
So there was a really comprehensive policy development process. This was assisted by the University of Queensland which was a consortium in conjunction with the Aged Care Industry IT Council and also PricewaterhouseCoopers. And where we started off was a review of available evidence about reporting systems across 18 different countries and we had a really rigorous process of stakeholder consultations with older Australians, their families and representatives as well as aged care providers and peak organisations. So in total we had 24 workshops with older Australians, residential aged care providers and peak bodies. We had 154 written submissions and we also held ongoing department reference groups which were attended by a number of senior Australians and also a number of the peaks including the Older Persons Advocacy Network.
We then moved to data analysis and benchmarking to determine what was good, acceptable or in need of improvement. And as Emma’s described that included the development of a risk adjustment model to enable fair comparison across homes with varying levels of care recipient acuity which again Emma’s gone into some detail about that. We’ve developed the algorithms which fed into the star ratings prototype that ingests real data and this was tested and refined with older Australians, their representatives, providers and care navigators. And then we sought Ministerial agreement to the star ratings design which we’re presenting to you today.
So through this process we’ve engaged with over 100 older Australians, their representatives, inclusive of people with dementia, people from culturally and linguistically diverse communities, people from the LGBTQIA community, forgotten Australians and First Nations people.
We’ve then been developing the IT required to capture the new data elements and enable publication of star ratings on My Aged Care which will continue to enhance following the go live. You’d all be aware that we worked on the primary legislation and the Parliament enacted that legislation to enable the publication of Star Ratings through the Aged Care and Other Legislation Amendment in the Royal Commission Response Bill 2022 and we’re working on communications and change and we’ll continue to release products and raise awareness through the various channels which again we’ll discuss a bit later.
So some of the key features I did want to touch on before we go into the demonstration was around new homes and transfer of ownership, certainly a question and answer that’s been appearing around this. So within the new Star Ratings system new aged care homes will have a new provider label displayed on My Aged Care. That will be for a period of approximately 12 months unless the home has been issued a decision of non-compliance. As sub-category data becomes available those sub-category ratings will be available but no overall Star Rating will be available until the home has all four sub-category ratings. In relation to Staffing and Quality Measures they will become available after two consecutive quarters or six months.
So now the more exciting bit. I think it’s potentially a little bit more tangible in any event. Provider preview. So in a nutshell as discussed we will be sending out a provider preview to people at least one week prior to publication and again what we want you to do with that is to check Star Ratings, have conversations with your residents and your staff about what it means. If your data looks different or incorrect please check the data reported to your home and also review the technical manual to understand why it may be different.
[Visual of slide with text saying ‘Section 4’, ‘Demonstration of My Aged Care Star Ratings’]
So we might now go into a demonstration of the My Aged Care Star Ratings and give you a bit of a preview of the look and feel for the IT that currently is underway. So we’ve started off there with a slide, the ‘Find a provider’ tool which enables older Australians and their representatives to search for a home that meets their needs. You can see here each provider page displays the overall Star Rating and four sub-category ratings. You’ll be able to use the search tool on My Aged Care and you’ll be able to search for an aged care provider using a range of criteria. So that will include location and availability, cost, care type, specialisations, language and faith.
If we flick through here you can see the Residents’ Experience and Compliance pages. You’ll be able to click to be taken to a page that explains the calculations in more detail as well as the simple display of information here.
The staffing page shows the staffing rating information, includes the case mix adjusted target minutes and the performance for the last quarter. The Quality Measures page shows the Quality Measures rating and again it includes information about each of those Quality Measures as a percentage of higher or lower than the national average.
So if we move through to resources we’ll talk about resources and next steps and then we’ll start to move to the question and answer session. So we’ve developed a suite of communication materials to support the publication of star ratings and they’re going to be available between now and December. It includes a provider manual with detailed information about the calculation and reporting requirements for Star Ratings, improvement focused materials, frequently asked questions, a how-to video guide explaining how to use the Star Ratings, fact sheets and posters. And we’ll use the feedback and questions that we get through these types of forums to update those resources as we go to make sure that we’re answering the questions that you have.
So the Provider Manual is now available on the Department’s website and again it provides detail of the Star Ratings algorithms and reporting requirements and it builds on effectively what you’ve heard in today’s webinar. So if you scan the QR code on the screen you’ll be taken to the link.
So we’ll move through to next steps. So in terms of key dates and next steps I want you to please read or watch the supporting materials including this webinar, fact sheets, the FAQs, again the how-to mini video as soon as these become available, and we have published those materials but as I said we’ll continue to push further products out through the various channels. So we’ll provide updates and links to communication materials. We’ll do it through newsletters. So please ensure you’re signed up to the mailing list for that. And as mentioned providers will be able to preview their rating at least one week prior to publication. If we can give you more time we will but I’m unable to commit to that at this particular stage. If you want to make sure you get your Star Rating preview – and this is something I’d really like to highlight is really important – please ensure your organisation administrator details are up to date. So to do this please log in to the My Aged Care portal, go to the ‘Staff Administration’ tile and review administrator roles assigned to your aged care home. There are some of you out there who haven’t kept their details up to date so please help me help you get a star rating preview by Monday if you could.
It’s really important to remember in my mind before we move on to some of the question and answers that this is the first iteration of the Star Ratings system. It’s something we intend on continuously assessing at regular intervals to understand how it’s driving the behaviour of both older Australians and providers, is it useful informing choice, is it driving provider improvement, how are we tracking as an aged care system. I know there’s a degree of apprehension by some providers about the unknown and it is a significant change for a sector that’s currently operationalising a number of complex reforms. But these reforms along with the Star Ratings system are landmark reforms and are intended to drive significant change.
So as uncomfortable as the Star Ratings may be for some providers at first it’s something we do need to embrace. It’s something as a system we need to embrace. Everyone on this webinar, in this room with me, in the aged care sector, we are all united in purpose. We want to deliver better quality aged care services and we want to rebuild community confidence in the aged care system. We can’t achieve this without greater transparency. Transparency is absolutely foundational to these landmark aged care reforms and to restore community confidence in all of us. There’s many of you out there already providing high quality care and others striving to do it. The Star Rating system really provides a key mechanism to help providers understand their performance relative to others, identify those areas for continuous improvement and for a number of you it’s going to enable you to showcase the great work that you’re already doing.
[Visual of slide with text saying ‘Section 7’, ‘Mythbusting’]
So what we do is we’re going to have time for a question and answer and what I thought might be really useful is we’ve been getting a bit of feedback both through the engagements that me and some of the team’s been attending and I’ve certainly read some of the media coverage with some interest. And so I thought I’d take the opportunity to properly correct some of the misinformation that might actually be out there about star ratings.
So we might jump through to the first myth that we have and that is if you don’t submit data you will not receive a rating. So not true. If you don’t participate in the Consumer Experience Interviews you will receive a one star in that category. If you don’t submit your quality indicator or your Staffing Minutes data on time you will receive a one star in these categories and these results will flow into your overall rating.
Jump through to the next one. So for Star Ratings to be meaningful they need to reflect Uber star ratings. So this one surprised me if I’m truthful. So the language and concept of Star Ratings for aged care, what constitutes a particular star was actually derived by talking to older Australians and channelling their view around what the stars mean to them. So a three star was seen as acceptable, adequate, average. Not dissimilar with views on other Star Rating systems too where this is actually interpreted as fine or solid. The Uber star rating doesn’t really resonate with this audience. We suspect it’s because 85% of users for Uber are actually under 45.
Having said that what stars can mean to people can change over time and so it’s something that we’ll be conscious of, constantly reviewing the Star Ratings system, what does it mean for older Australians and how does it drive behaviour. If we jump to the next one.
So here we’ve got the focus of care minutes is too narrow as it does not include allied health or lifestyle staff. And I might invite my colleague Mark Richardson. Mark are you online there?
I am indeed.
Mark would you like to take this one away?
Yeah sure. Thanks Josh. Look it’s an interesting characterisation to say that the care minutes definition is narrow. I think I’d argue that rather than narrow I’d argue that it’s accurate and consistent with the Royal Commission recommendation. That recommendation was the inclusion of registered nurses, enrolled nurses and personal care workers. My understanding of the basis of that was that people weren’t receiving adequate care in relation to showering, toileting, medication and those sorts of things. Funding has also been provided to ensure that we’re increasing the number of registered nurses, enrolled nurses and personal care workers. So I think the inclusion of other types of professions, lifestyle workers and allied health would potentially water down the intent of that recommendation and would also be inconsistent with the funding that’s been provided.
And look as we’ve said before Josh I think in other forums there is funding I should say within AN-ACC for both lifestyle and also allied health and indeed they’re expected to be delivered when in a care plan and the Aged Care Quality and Safety Commission will be monitoring that.
So we might jump to the next myth that we’ve got up there which is the Australian Star Ratings system is based on the United States system which has given way to a flawed system. So when Government announced its intention for a Star Ratings system one of the first things both Emma and I did was jumped on a video-conference with our colleagues in the United States who are ten years ahead of us with a Star Ratings system. And we asked ‘What have you learned? We don’t want to make the same mistakes’. And we’ve kept those conversations going. And the issue with the United States system is around the accuracy of data which is self-reported by providers which makes up the majority of their ratings. In Australia 63% of our score is derived from data which is independent from providers. So we’ve got 33% across consumer experience, 30% across regulatory activity from the Aged Care Quality and Safety Commission. And so beyond having an overall rating of stars and sub-categories the rating systems are comparable.
Another one that we have had is that service compliance ratings are not fair as the Commission’s regulatory processes don’t afford providers procedural fairness. Emma J, I might hand that one over to you.
Thanks Josh. So I think importantly to understand that under the legislation the Commission is required to provide procedural fairness in its decisions and this can include opportunities for providers to provide additional advice and evidence to decision makers. So by the time a decision maker completes the original decision of non-compliance providers will have had opportunity to provide evidence of their non-compliance through the Commission’s engagement and monitoring processes and often prior to the finalisation of those decisions. For example prior to the preparation of a performance report which details a service’s compliance with the Quality Standards the provider is given a full copy of the assessment report and the opportunity to provide further responses to any potential non-compliance before that decision is finalised in the performance assessment report.
In addition following a non-compliance notice a provider is given a further opportunity to provide evidence of their compliance prior to submitting their undertaking to remedy to address the non‑compliance.
I think in the aged care context though procedural fairness needs to be balanced against the primary objective of protecting and enhancing the health, wellbeing, safety and interests of aged care consumers. And what that means is that the Commission Act does recognise that there are some regulatory actions that may need to be taken urgently such as when there is evidence of risk to consumers and this occurs through the issuing of a Notice to Agree or sanctions are imposed.
So broadly if after engaging with the Commission providers still do not agree with decisions of non-compliance there are formal reconsideration pathways they can use as well. The Commission has a regulatory bulletin on reconsideration of reviewable decisions on our website and we’ll be able to provide links to that hopefully in the chat on this webinar too.
So the next one that we heard is that the sample of interviewed residents is not representative of the actual residential aged care cohort. And so we understood that there were people out there saying that there were also other issues that may not make sense in the results if it’s coming from a population that might not have English as a first language and that we wouldn’t be interviewing people with cognitive issues such as dementia which are obviously quite prevalent in aged care. So I might tackle a few of those issues.
So in terms of the sample being interviewed from a statistical perspective it is representative. If you do have concerns I’m happy to engage you in a dialogue with the statisticians because I’m actually certainly not one myself so we’ve taken the relevant expertise on board there. We’ve interviewed nearly 19.4%, actually 19.6% so nearly 20% of residents across Australia and we’ve done a minimum of 10% per home but depending on its size it varies. So the smaller the facility the greater the percentage we interview to ensure that privacy is maintained and to ensure statistical validity as well.
We’re targeting 60% of the general population and also oversampling special needs at 40%. Where people need a translator or support person to assist in communicating this is provided. We have used proxies in around 12% of those interviews however in both our methodology and execution we’ve channelled the clear direction of the Royal Commission and that is that there needs to be a presumption of capacity. And so we’re speaking to as many older Australians directly as we can. So in addition to the support mechanisms I’ve described we have visual aids, if residents are unable to meaningfully engage or don’t want to start or continue interviews we move on to other people there.
So we might jump to the next one. So Mark I think this is going to be one for you. If you get a three star for care minutes for meeting your targets Government must be funding a three star system. Mark over to you.
Thanks Josh. Look this is an interesting one. I think it’s a little bit misleading to be quite frank to link the concept of if you meet your target that means the Government’s delivering a three star system. I think it’s completely inconsistent with the evidence that’s out there. So at the moment the sector’s delivering on average 180 minutes of care time. The Government is investing billions of dollars to lift that to 200 minutes, then 215 minutes, and it’s also investing to deliver 24/7 registered nurse care. So I would not be linking it and inferring that somehow it’s a three star system as a result.
Look secondly I think if you were to go down this path – I mean personally I think it’s right to be quite frank – if you meet your targets you get three stars. If you go above your targets you get four or five. As I was saying I guess if you go the other way as it infers and if you meet your targets you get five stars I think there’s two potential outcomes or scenarios with that. First of all everyone gets five stars which I think would probably be a little bit inconsistent with what we’re trying to achieve with star ratings, enabling consumers to be able to compare facilities, and we’re back to square one again. The second outcome would be I think you’d have potentially some facilities that only decide to deliver three or four stars and not even try to reach for the five stars. Once again I think that would raise questions around why Government’s funding to get to the five stars and allowing facilities only to deliver three or four. So I don’t think it would be a fantastic solution anyway from a design perspective. I think it’s right if you deliver your targets you get three stars. But most importantly it doesn’t mean that it’s a three star system. As I said the evidence is out there, 200 minutes, 215 minutes and 24/7.
[Visual of slide with text saying ‘Section 7’, ‘Questions and Answers’]
Thank you Mark. So look we might jump into the question and answer session. We’ve had a lot channelling through and I can see that they’re starting to channel through to me as well. So I’ve got Emma to help me with any questions around Star Ratings. We’ve got Mark Richardson on the line to do care minutes or the QFR process, Quarterly Financial Report process, and obviously we’ve got Emma Jobson here as well to answer any questions that we’ve got coming in about the Aged Care Quality and Safety Commission activities.
So I might just start to have a look at the questions that are coming through here.
So the first one [0:37:50] giving providers a preview of their rating for at least a week. If we can do more than that we will do it. And as soon as I have more information and can give you specific dates and lock those in we’ll publish that and we’ll get it out to you through the various channels we have including the BIDS messaging system.
So okay this is a good one.
Q: So what services will star ratings apply to?
So as I said star ratings will be published for all aged care homes on My Aged Care by the end of 2022. The star ratings will not currently apply to in home care, to National Aboriginal and Torres Strait Islander Flexible Aged Care and multi-purpose services program services. So those services don’t currently have all of the data feeds that we spoke about or all the four kind of sub-categories of data that feed into produce a star rating so they will not have star ratings applied at this time. It will be residential aged care services.
And I should say over time star ratings could be enhanced or could be expanded but that remains subject to decisions of Government. So it is limited to aged care homes at this point.
So the next one I’m looking at I think – Emma J I think this one is for you and it’s:
Q: How do compliance ratings benefit providers?
Thanks Josh. As we all know Star Ratings are principally for consumers, their families and carers to compare and help them choose services. But for providers as I think Josh was saying earlier it also promotes the importance of continuous quality improvement to provide assurance to consumers that providers are demonstrating their improvement and performance. It’s also really useful I think in that it’s an at a glance way for providers to understand their own service’s compliance status and how they compare to other services. And overall this is increasing the accountability and transparency as we discussed earlier and in turn fosters greater public trust in the way a service may be operating, whether they are performing well or they’re working hard to improve.
So we’ve had a few different questions coming in about the inclusion of particular roles into care minutes. So Mark I reckon you’re best for this one.
Q: Why is allied health not being included in care minutes for Star Ratings?
I think I may have answered that one but I guess to go over that the Royal Commission clearly made a recommendation that 200 minutes of care was associated with RNs, ENs and PCWs. I think the key thing, just to add to what I said before, that doesn’t mean that the expectation is that allied health services will no longer be provided in residential aged care facilities. It’s exactly the opposite. Facilities are still funded for and expected to provide those services consistent with the care needs of residents. And once again Emma, the Aged Care Quality and Safety Commission, will be looking out for that. So we’ll provide data that we’re collecting through the QFR in relation to the provision of allied health time. So there’s five professions in there. I can’t remember them all off the top of my head but there’s physiotherapy, there’s podiatry, dietician and a couple of others. We’ll be providing that all through to the Aged Care Quality and Safety Commission so they can keep an eye on that.
Okay. Thanks Mark. So we’ve got another question which I think we’ve covered but we’ll address it just for clarity and that’s around when will the star ratings be updated. So the question we got was:
Q: Will star ratings be updated quarterly?
Emma did you want to take that one away?
Yeah sure. So I know it’s hard to keep track of with all the different feeds and frequencies but the short answer is yes. There will be a regular cadence of update and reporting. So following on from the Staffing and quality indicator data or Staffing and Quality Measure data being submitted quarterly there will be a process of then the provider preview allowing service providers or aged care providers to review their ratings prior to publication and then publication. The annual consumer experience data will fit in with this quarterly kind of cadence so that will follow the same. The only exception to that will be the Compliance Ratings which change on a daily basis as the information flows through in what is pretty close to real time.
Thanks Emma. So we’ve got a lot of questions coming through which is great. I’m hoping we’re going to get to most of them but if we don’t again what we’ll look to do is update frequently asked questions. I think the next one I’ve got Emma Jobson, this is probably for you, and it’s about:
Q: What do I do if I have concerns about my service’s compliance rating?
Yeah. So I think providers should seek further information from the Commission if they’re unsure about or even disagree with their Compliance Rating. Providers can contact the Commission’s customer contact team on email. It’s email@example.com or 1800 951 822 and those details will be posted on the chat in the webinar.
If a provider has current compliance action in place and they believe they’ve already provided the evidence of their compliance to the Commission or they wish to know the progress on the decision to close the compliance action they can contact the Commission at the contact centre or they can use the contact details that would have been on the original compliance notice. The Commission will also have a specialist team on hand to troubleshoot any technical issues around the Compliance Rating with providers and the Department as we progress.
Cool. All right. So we’ve had another one come in. I think this one’s probably for you Emma C.
Q: Will there be the ability for a service to indicate why that service may rate lower than expected?
Yeah. So the ratings themselves are obviously all standardised and in the format that we’ve walked through which is really important to allow clear, simple ratings that older Australians and their representatives can use and that are comparable across all aged care homes. In saying that providers have an opportunity to enter free text and that’s in the summary information that’s displayed on My Aged Care. Providers can do that by accessing the provider portal and updating that information and it’s a really good and existing opportunity to provide older Australians and their representatives with more information about your service offering. And that could be contextual information about specialisations or different aspects of your service or areas that you’re working on or recent improvements that you’ve made.
Cool. All right. I’ve had a couple come in on consumer experience interviews. One of them was saying:
Q: You said at least 10% of aged care residents have been interviewed but why not the 20% previously committed?
So just to clarify what I did say is that whilst at least 10% of care recipients at every aged care service is being interviewed, on average we’ve done 20% and we’re looking at I think – as I said I think it’s about 19.6% across nationally at this particular stage.
We also had a question on the CERs which is:
Q: What if a service chooses not to allow residents to participate?
Yeah. So I think I may have mentioned but if an aged care home chooses not to allow the third party workforce to speak with care recipients or with older Australians and to get the resident experience surveys completed then they will be allocated a one star rating. Obviously we all know how crucial it is to hear the voice of older Australians and to hear the experience of those older Australians living within aged care homes as well as to use that information to support improvement. So it’s crucially important. And consistent with the other aspects of data included in the star ratings including quality indicators and care minutes not supplying the data will not result in no rating or will not result in a default rating. It will result in one star for the sub-category and for that element feeding into the overall Star Rating.
Q: What do I do if I disagree with the Commission’s decision in relation to my service’s compliance?
So I think the Commission expects providers to proactively engage and have ongoing communication with the Commission about their non-compliance and the steps they’re taking to address it.
The processes around procedural fairness as I outlined earlier allow providers numerous points in the monitoring and decision making process to address concerns the Commission raises about their compliance. And as I outlined earlier there are circumstances where the protections required in terms of risks to consumers may override that on occasion. There are also formal reconsideration processes providers can access around most decisions and they’re detailed in our reconsideration of reviewable decisions regulatory bulletin on our website.
We had a question.
Q: Will the slides be distributed and how?
That’s an easy one. We’ll make it available up on the website.
We’ve got a question here around – not surprisingly. This is a reasonable question.
Q: What if there’s an issue with my rating?
Emma do you want to do that one?
Yeah sure thing. So first and foremost providers will have an opportunity to preview that rating at least a week prior to publication. So I would encourage you as Josh has said to make sure your administrator roles are up to date in My Aged Care. You have until the end of Monday to do that. If you’re having any trouble doing that then do contact the My Aged Care Provider Assessor Helpline. They can support you further. And ensure that you ask for tier two support to help you update those accesses and roles.
So once you’ve done that and you’ve received your provider preview look at it and if something doesn’t look right I’d say the first thing to do is to go back to the original data sources, to go back to – if it’s the Quality Measures component go back and check the quality indicator data that you submitted. Go back to the care minute data that you’ve submitted in your financial report and cross check there. If it still doesn’t look quite right it can be worth having a look at the provider manual. You certainly would have noticed as I spoke through the calculations there is some complexity and some of those do change figures slightly such as through risk adjustment of a quality indicator which might show you a slightly different number to the one you reported or it may result in case mix adjustment of your care target. So if you were just looking at the 200 that may change slightly for your service. So do review that manual and ensure that you understand how it was calculated. That may give you the answers but if it doesn’t and you believe that a technical or an IT error has occurred at any stage you’re very welcome to call the My Aged Care Provider Assessor helpline and they have been really well trained to talk you through the next steps and to help you further.
Thanks Emma. So I think Emma Jobson next one for you. We’ve got another on compliance ratings and it’s:
Q: How quickly can we improve our Compliance Rating?
Thanks Josh. So with an existing compliance or enforcement action in place a service will have a reduced Compliance Rating of one, two or three stars. So for a service to improve their rating from one or two stars they will be required to address the non-compliance or to have a sustained compliance for at least 12 months. So the timeframe will vary based on the type of the non‑compliance decision, the actions required to address it and the process of evidence to make a decision on resolving the compliance. For a service to improve their Compliance Rating from three stars to four or five the requirement is basically time. For a four star rating providers will be required to have had no non-compliance for 12 months or more. If there is a current direction to revise a plan of continuous improvement it must be closed before the 12 month period begins.
For a five star rating providers will be required to have had no non-compliance for three years or more and have been accredited for a three year period. As Emma said earlier all changes to the compliance ratings are updated daily on My Aged Care.
Thanks Emma. We’ve had a question around quality indicators.
Q: Are the new quality indicators included in the star ratings?
I could probably answer that one. No. Not at this particular stage. So the only quality indicators feeding to the Star Ratings system are the existing five indicators that we’ve got. If we were to feed any further quality indicators into the Star Ratings system at a future date it would be absolutely subject to a decision by Government in the first instance.
Another question about CERs we had.
Q: Can you please provide examples of questions the care recipients will be asked during those consumer experience interviews?
So yes we’ve published those. So they’re available on the Department website. So there’s 12 questions which have a Likert scale response and then we have two questions seeking qualitative information.
We have another question again about Compliance Ratings.
Q: Does a Compliance Rating of one or two star mean I cannot get a higher overall Star Rating?
Emma C you spoke about this so I’ll hand that one to you.
Yeah that’s right. So if a one or two star rating is awarded for the compliance sub-category that will be the same rating that’s applied to your overall. Now that doesn’t mean that you can’t show good performance in other areas. You’ll still have sub-category ratings displayed for Quality Measures. You’ll still have those ratings in the information accompanying Residents’ Experience Ratings. So there’s still an opportunity to show good performance in those areas but that result for the Compliance sub-category will limit you to the same rating overall.
So I’m just having a look.
Q: Can I opt out of the Star Ratings?
No. I can probably handle that. No. You cannot opt out guys.
I’m just having a look to see ones that we haven’t already covered.
We could probably go for:
Q: What happens in relation to transfer of ownership, the transfer of service?
Emma would you like to take that one away?
Yeah sure thing. So for a new service or a service that’s recently been taken over by new ownership by a new provider their star ratings will – well they won’t have a star rating to begin with. As we spoke about it will take approximately a year for the full ratings to be populated and the reason being that the Staffing and Quality Measures sub-categories will be populated after six months, the Compliance and consumer experience sub-categories will be populated once information becomes available. So that’s typically by one year for Compliance unless there’s been an interaction with the regulator sooner. And for consumer experience it will depend on when those Residents’ Experience interviews have taken place.
So you’ll have up to one year. And the only other thing I should say is that we will have tables saying the history or performance over time for star ratings which we’ve heard both from providers and older Australians and their representatives are really important to show improvement over time and really valuable. Those will also be clear and there will just be a note acknowledging that there was previous ownership of the service and linking someone or allowing them to press on that link to see that previous service name or ownership or details. So it won’t be carried over to a new approved provider or a new owner.
Okay. Next question through. This one’s probably for you Mark and it’s:
Q: Why can’t we count ENs with RNs in the Star rRatings?
They’re two different qualifications. Registered Nurses, the scope of practice for Registered Nurses I think is somewhat higher than Enrolled Nurses. So by and large these days Registered Nurses do have a Bachelor degree. There are some Registered Nurses I think a while ago that may have gone through a different qualification process. But I think at the end of the day Enrolled Nurses operate under the direction of Registered Nurses and as I said by and large haven’t done that Bachelor degree. So I think it makes sense that ENs are part of the PCW bucket, 160 minutes, and RNs are separate. The RNs are the ones that I guess – as I said their scope of practice is significantly higher around medication management and other things. They’re the ones providing that team lead and direction to ENs and PCWs.
Thanks Mark. So we’ve got one about historical data.
Q: Will historical Star Ratings be available for the public?
So the answer to that is yes they will be available for up to three years of data on My Aged Care once available.
We’ve got two minutes to go.
What I might ask next is:
Q: How will Star Ratings actually support provider improvement?
Emma did you want to answer that particular one? Do you want me to have a go or do you want to do it?
Yeah. I mean I’m very happy to. Or maybe both.
You’re the model expert so I’ll let you do it.
I guess the key to improving a star rating is to improving each of the sub-categories that sit beneath it. And so I know it’s a big change and it’s a new system and certainly we will produce specific improvement materials to support you in the context of Star Ratings. They will be made available on the Department’s website in the coming weeks. But if I walk through each aspect of the Star Ratings and think about improvement, we have consumer experience. I’ve seen questions coming in around consumer experience, what are the questions that are included? Those you can currently find in our summary report and you’ll find them in the provider manual as well. And you can start I suppose by looking at the results for your service and looking at the areas that residents felt needed improvement and starting to have that open discussion with older Australians and their representatives about what that improvement could look like and engaging with and having meaningful conversations with the people at your aged care home about what they’d like to see. So that’s just a practical example.
Compliance of course, if you’ve got a one or two star you’ll be working actively with the Aged Care Quality Safety Commission on improving the areas relevant to your service. With respect to staffing you’ll have your targets available in the portal and you’ll know now how you’re performing against those targets. So that will provide an opportunity to start to move up the performance rating for that sub-category. I should also note with respect to workforce turnover, which we know can be a difficulty, the new quality indicators will be targeting that area and the new Part B of the manual, QI Program Manual Part B will have a specific section dedicated to improvement and to tangible activities that can be used to target workforce or enhance workforce retention.
And finally Quality Measures. It’s probably relevant that I’ve just mentioned QI Program Manual Part B which is a dedicated resource that’s really been put together based on contemporary evidence and best practice materials about improving quality indicator outcomes and reducing those prevalence rates. So it gives a range of tools including the plan, do, check, act cycle that Josh mentioned that providers can use, and we encourage you to engage with to improve across a range of areas including those quality measures that are published through the Star Ratings. But there will be more to come.
Thanks Emma. So look conscious that we are running a little bit over time. There were two questions I’ve seen that have come up and I think they’re really easy to answer so I’ll quickly address them and then we’ll look to close. So it was:
Q: Will MPS be included in the Star Ratings?
So the answer to that is no. Currently neither MPS or NATSIFAC services will be in the star ratings because they don’t report the data required.
And again we’re getting a number of questions around the Compliance Rating. So I just put the contact details out there that Emma talked about to the Commission’s customer contact team. So the email address there is firstname.lastname@example.org and the number there is 1800 951 822.
Again I want to thank you all for being on the line and taking the time to be with us here today. I’m conscious that you want to know more about the Star Ratings system. I’m conscious that you want specific dates as quickly as possible and so we’ll be looking to continue to communicate through those channels. We haven’t gotten through all the questions today but what we will do is draw those up and we will have a look at revising our frequently asked questions.
So again thanks to everyone today and look forward to connecting with you all soon. Thank you.
- Josh Maldon – Assistant Secretary, QAD Choice and Transparency Branch
- Emma Cook – Director, Star Ratings Section, QAD Choice and Transparency Branch
- Mark Richardson – Assistant Secretary, HRD Residential Care Funding Reform BR
- Emma Jobson – Executive Director, Regulatory Policy and Intelligence at the Aged Care Quality and Safety Commission