Home Care Packages (HCP) Program Assurance Review on excluded items – Webinar

[Opening visual of slide with text saying ‘Australian Government with Crest (logo)’, ‘Department of Health and Aged Care’, ‘Home Care Packages (HCP) Program Assurance Reviews’, ‘Review 4 – Excluded Items’, ‘Introduction:’, ‘Chamandeep Chehl’, ‘Assistant Secretary’, ‘Program Assurance Branch’, ‘November 2024’]

[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]

Chamandeep Chehl:

Thank you all for attending today’s webinar. I’m Chamandeep Chehl and I lead the Program Assurance Branch in the Quality and Assurance Division of the Department. Today it is my pleasure and honour to host this event. I would like to begin by acknowledging the traditional owners of the lands you are joining from today. The traditional custodians of the lands I am meeting on today are the Ngunnawal people and I recognise any other people and families with connection to the lands of the ACT and region. I acknowledge and respect their continuing culture and the contribution they make to the life of this city and this region. I also acknowledge and welcome all other Aboriginal and Torres Strait Islander people attending today’s event.

This is our third review related webinar. We combined reviews two and three into the same webinar. So I won’t detail who we are and what we do as a branch and why we do Home Care Packages program assurance. However feel free to raise such questions at the end of the presentation and the panel will be happy to answer.

We have chosen to use MS Teams today which has a limit of 1,000 registrations. Unfortunately we did underestimate the interest in this webinar and some people may therefore have been unable to register. We’re really sorry about that but the webinar presentation has already been published and a recording of the webinar will be available on our website shortly. A question and answer document will be added to our webinar page later.

This afternoon we have an hour long webinar inclusive of a question and answer session. Thank you to all those who sent questions through ahead of the webinar. We will however be only answering review specific questions today given the nature of this topic. All other questions where possible will be answered through the responses we post online over coming days. This means please note that we won’t be answering questions on individual care recipient exclusions or matters outside of the review, for example Support at Home related questions. Obviously we appreciate there’s a lot of interest in Support at Home so you can stay up to date with upcoming webinars, information and resources about Support at Home by subscribing to the Department’s newsletters. You can also register now for the upcoming In Home Aged Care webinar for providers on the 5th of December 2024. Links to both of these will be provided in the chat function.

During the webinar there is no option for attendees to turn on their video or microphone. We will also be recording today’s session and uploading it to our website along with the slides. Joining me today will be co-panellist Mark Rummans, Director, Program Assurance Reviews. Also joining us are two members of my team, Jennifer Young and Sue Secko. Jen and Sue are actually going to take you through today’s presentation. 

Before I do hand over to them however I really want to take this opportunity to publicly thank the 103 providers who participated in review number four, excluded items. We really appreciate your good faith, engagement and feedback. We have a strong inward facing continuous improvement culture in our branch and we take great pride in this. So any formal or informal feedback you’ve provided for review number four or other reviews is incorporated into our future review considerations as appropriate. As you go on the journey of this review with us today I hope you can see the applied benefits of Home Care Packages Program Assurance Reviews for providers but ultimately and most importantly for care recipients and the public.

With that I’m now going to hand over to Jen. Thank you.

Jennifer Young:

Thank you Chamandeep. Good afternoon everyone. My name is Jen. My colleague Sue and I will be presenting information on why and how we did the review and what difference the review made. HCP Program Assurance Reviews support enhanced transparency and accountability in aged care. This continues with the release of the fourth Assurance Review Report on the Home Care Packages Program. Providers are accountable for appropriately spending program funding so care recipients get value for money from the care and services that they are approved for. Through Assurance Reviews the Department also wants to help the vast number of providers who are doing the right thing. Ultimately findings and guidance from this and previous reviews arm care recipients with information to clearly determine what their HCP Program funds can and are being used for and what they are being charged.

The Commonwealth on behalf of the taxpayer has invested significantly in the allocation of program funds. As at the 31st of March 2024 there were 900 approved providers delivering care and services to almost 285,000 older people with $7.7 billion of Commonwealth funding allocated to the program in the 2023-24 financial year. To address the projected increase in demand the Australian Government’s 2024-25 Budget announced a further $530 million of funding to be allocated to the program. This allocation will fund approximately 24,000 extra packages, hence the Government and the Australian public must have confidence that providers are delivering care and services that older people need and are for approved purposes under the program.

You may ask what is an excluded item. As defined within the legislation and the Department’s guidance material an excluded item is an item or service that is not allowed to be purchased with Home Care Packages Program funding. HCP providers must not purchase care and services that are identified in the Quality of Care Principles 2014 as being excluded. For example HCP Program is not an income support program and cannot be used for goods or services people are expected to cover out of their general income throughout their life regardless of age. Nor can care and services already funded through other Government programs be funded through the program. The HCP Manual provides detailed advice and case studies on inclusions and exclusions to further support providers and care recipients.

Providers can use the inclusions and exclusions framework which is found in Part 9 of the Manual when making decisions on what can and cannot be included as part of a care recipient’s package. The framework supports providers to take a flexible and responsive approach to working with care recipients and deciding whether or not to provide proposed care and services that are not clearly specified in the legislated inclusions. Care recipients should be actively involved in deciding how their package funds are spent including considering any legislated exclusions. Providers need to work with care recipients to ensure that funding is used appropriately and transparently. Providers should document all discussions and decisions surrounding inclusions and exclusions in a care recipient’s case file. Providers must consider an individual’s circumstances and ensure expenditure of program funds align with the care recipient’s assessed care needs in their care plan and with the intent of the program. 

I will now hand over to my colleague Sue.

Sue Secko:

Thank you Jen. So why was this review undertaken? The Department is responsible for good program administration. This review provided an opportunity for us to ensure that funds are being spent on allowed services and goods. We also timed this review a few months subsequent to the release of the revised 2023 HCP Manual to provide the sector with an opportunity to consider all updates. Additionally three of the key questions why we undertook this review are three key reasons. 

One. Spending of program funds on potentially excluded items was identified in three previous Program Assurance Reviews. Examples included fuel gift cards, TVs, holidays, including flights and accommodation, IT equipment and [0:08:39] food component of meals. Reviews one to three each had specific scopes however incidentally each review informed the Department’s thinking concerning excluded items and the requirement for a detailed HCP Assurance Review on this matter.

Two. Evidence demonstrates ongoing confusion from the sector concerning program inclusions and exclusions despite the revised Manual. This includes regular enquiries from providers on inclusions and exclusions to the program area and state and territory offices and via the online Program Assurance Community of Practice. During previous reviews it was identified care recipients are also not always aware of what is excluded under the program or pressure providers. Despite any pressure from care recipients or their loved ones providers remain accountable for package expenditure.

And thirdly our assurance work seeks to support current program delivery and future policy and program development under Support at Home from 1 July 2025. Ultimately we want to support continuous improvement and an uplift in the understanding of providers and care recipients. We also want to work with providers to remain vigilant to misuse, error and potential fraud.

This review sought to answer the following key questions. Was there expenditure on excluded items? If so how widespread is this issue? And finally why was there spending on excluded items?

We selected 103 providers based on a few considerations and risks including providers identified from previous Program Assurance Reviews and other intelligence before the Department. A random sample of 1,824 care recipients was selected for review. Care recipient sample sizes were set according to provider size. Care recipients needed to be actively receiving services at the time of the review and their services must have started before 1 January 2023. Providers were required to submit monthly statements for April, May and June 2023 for examination. These totalled over 5,000 monthly statements.

We also want to take this opportunity to note before moving into findings the procedural fairness that was afforded to all selected providers throughout the review. For example providers received draft reports to review and submit management responses before reports were finalised. Participating providers were also offered an opportunity to attend entry and exit meetings and ongoing engagement to clarify requirements with review officers.

Jen will now take us through the review findings.

Jennifer Young:

The review found evidence of program funds being spent on excluded items with 377 items determined as excluded. The review found 62 of the 103 providers or 60% had spent HCP funds on excluded items. Of these 16 providers had one exclusion, 24 providers had between two to four exclusions and 22 providers had five or more exclusions. This spending ranged from $10, for example on vitamins, to $10,000 for example on the purchase and installation of an air‑conditioner. Across the 103 providers more than $124,000 was spent on excluded items. This means that the average amount of funds spent by selected providers on excluded items over the three month review period was approximately $68 per care recipient. These review findings demonstrate the need for further provider monitoring and education.

So as noted in the previous slide the average amount spent on excluded items per the care recipient sample was roughly $68 over the review period. In seeking to understand what this spending might look like across the broader sector the review team determined that if the $68 of spending is roughly consistent across all care recipients in the program and if the $68 was projected over a three month period for all 250,000 plus care recipients the total money spent on excluded items could be around $17.6 million. More broadly if the $68 was projected across a full year and calculated across the total program potentially $70.5 million per year from the program could be leaking due to the purchase of excluded items.

We acknowledge this is a relatively small proportion of the $7.7 billion of program funds however this is still a significant risk to the program. Any amount of misapplied funds is of concern because it reduces the program’s value for money for both care recipients and the public. Our findings suggest the need for further education for and attention from providers on what package funds can be spent on. We have a Community of Practice for this purpose which we cover later in this presentation. 

Please note that while these findings are based on robust data collection methods the displayed calculations come with limitations. Specifically the selection of providers was risk-based and chosen on specific criteria relevant to the review. Consequently this sampling may introduce some bias however some of this bias has been offset by the random nature of sampling of care recipients within the provider selection process.

So why were Home Care Package funds being spent on exclusions? The review found more than half of the excluded items were purchased with program funds because the provider claimed that they misunderstood the Quality of Care Principles or Program Guidance. While the review team acknowledged there are a small number of areas Program Guidance could be strengthened overall the review team found the Guidance to be both comprehensive and clear. Other reasons included lack of staff knowledge or staff errors, alleged pressure from care recipients or their representatives and lack of sound provider administrative processes or decision making. Some reviewed providers had no clear explanation due to poor record keeping practices and some had more than one reason per exclusion in which case the main reason was counted in our data.

Our analysis identified the top five most commonly identified exclusions both in terms of the number of exclusions and by how much was spent on exclusions. The diagram on the left shows that medications, vitamins and supplements were the most common type of exclusion with 65 items or 17% of the total. The diagram on the right shows that home modifications or major home maintenance was the highest exclusion based on dollar value and this category of exclusions totalled $44,000 or 36% of the total. Gardening and landscaping, minor home maintenance and phones and tablets stand out as both frequently identified items as well as significant in spending. And this demonstrates that these three categories of exclusions are particularly important and were identified for potential further sector guidance.

In conducting the review the review team attempted to walk in the shoes of providers and care recipients to better understand their experience and perspectives, therefore where needed point out if Program Guidance needs to be clearer. For example further information on what is included under light gardening and home maintenance and what is excluded. Practical examples to demonstrate how HCP funds can be used to maintain a person’s functional safety in the home and where this support goes beyond the intent of the program. Reviewing public advice in the limited situations where HCP funds can be used to purchase a phone or tablet to ensure it is consistent. The Public Summary Report expands on each of these findings. And we are also pleased to advise that as of November 2024 a further revised HCP Operational Manual has been released listing additional specified inclusions and exclusions. And we hope that this update clarifies information regarding the use of HCP funds for these purposes.

I will now hand back to Sue to discuss additional findings identified during the review.

Sue Secko:

A range of additional findings or otherwise known as incidental findings were also identified during the assessment of monthly statements. While not directly in scope of this review as part of good program governance we pick up on such findings to support providers to understand their program related legislative requirements and identify these in individual provider reports.

A finding of particular concern was the persistent lack of clarity in monthly statements. This finding will be discussed further in the next slide. Further additional findings related to incorrect charges or charging practices including separate charges for third parties, carer package management including charges above the caps, and charging package management when no services were delivered in the month. Providers were requested to review other care recipients outside those in the sample and to refund amounts into care recipients’ packages where an overcharge was identified.

Pricing transparency issues, for example prices missing from full price lists and inconsistent prices published between My Aged Care and the provider’s full price list. The public summary report expands on these findings.

84 of the 103 providers had one or more issues with their sample monthly statements. These statements did not provide sufficient clarity or appropriate level of itemisation. This impacts care recipients’ ability to understand the types of care and services they received. Monthly statements are a key program control to support care recipient choice and transparency and is a legislated requirement. 

As displayed in this slide 72 of 103 providers or 70% did not clearly identify what item or service was provided to the care recipients. For example providers used manufacturers’ names, brand names for items rather than a more descriptive term, for example walking frame, or used broad generic descriptions such as purchase or home care.

The next issue related to the lack of itemisation of line items. 44 of the 103 providers or 43% were found to have not separately itemised services. Items were bundled into a single line item making it difficult for the care recipient to understand the care or service that had been delivered and the timeframe associated with that service delivery. To meet legislative requirements providers must include an itemised list of each item of care and service delivered in the month including total and line item dollar amounts even when delivered by third parties.

In monthly statements 41 of the 103 providers or 40% listed goods and services delivered in earlier months. Providers are reminded monthly statements must list the services and goods delivered that month not when they are invoiced.

The last column relates to unspent funds not being displayed as required on care recipient monthly statements. 11 of the 103 providers or 11% were found to have not separated out unspent funds in the required categories. As presented in the User Rights Principles each monthly statement must show the total unspent funds at the end of the current and previous payment periods.

Findings related to monthly statements have been identified since the commencement of Program Assurance Reviews. The team has reviewed 11,000 monthly statements to date as part of its review activities. The Department has a best practice monthly statement template on its website. It is not mandatory to use in terms of format and presentation however the information to be included is mandated via the User Rights Principles.

Obviously detailed and meaningful monthly statements ensure care recipients and their representatives have a clear understanding of their HCP program services, charges and account balances. Monthly statements are very important to care recipients. You could think about them like your bank statement. They tell you what funds you have available in your HCP package, what funds were used and for what purpose in the last month.

Given the lack of clarity of monthly statements evident through this and previous reviews the public summary report provides guidance for care recipients regarding reviewing their monthly statements carefully and keeping their provider accountable. This guidance is also available as a separate fact sheet titled ‘Additional Guidance for Care Recipients’ on the Department’s website. Some steps selected from the guidance on this slide for our care recipient audience and potential Home Care Package recipients to consider include check your monthly statement is clear and supports you and those who assist you to know what your program funds are being used for and what you are being charged. 

Check the good or service mentioned in your monthly statement was actually delivered or received by you. You should not be charged for package management in a statement month if you did not receive any care or services other than care management. You should not be charged more than 20% of your HCP level for care management or more than 15% for package management. This is now legally capped. Your account should not go into deficit. If your monthly statement does have a negative balance talk to your provider in the first instance. If that does not help contact the Commission.

Ultimately your provider remains responsible for the correct use of program funds and should explain to you clearly why a request you make cannot be purchased including if it is an excluded item. Don’t be lured by providers with promises of being able to fund what your current provider has said it cannot legally fund under the program.

Moving on. Some of the positive review outcomes included providers reviewed all care recipients for any excluded items identified and ceased the provision of those items. Providers have implemented new organisational practices and governance checks. Whilst not requested some providers refunded the funds that were spent on excluded items back into care recipients’ packages. Providers have conducted staff training on program inclusions and exclusions and decision making frameworks. Providers’ consistent application of the legislative requirements will support their staff to more confidently engage with care recipients to explain why something cannot be purchased.

Providers have investigated and implemented new software to assist with the production of monthly statements. Providers have engaged with third party suppliers to improve timeliness of invoices. This demonstrates provider knowledge on program inclusions and exclusions has been uplifted and care recipients can expect greater transparency in decisions on package expenditure and in the statements they receive from providers. Overall during the review period and the weeks following the final reports most providers closed out issues.

The review team sought feedback from providers to understand how the Department could improve its Program Assurance Reviews. In total 45% of providers that participated in the review responded to an anonymous survey. Responses were very positive about how the review was conducted. Providers found the review helped them identify ways to continuously improve their services, assess how well they are meeting program requirements and to find opportunities to improve existing systems and practices.

Some examples of positive feedback from respondents are evident on this slide. The quote referring to the report relates to individual provider reports which were issued to participating providers.

The review team will continue its practice of obtaining structured feedback from participating providers through surveys at the conclusion of reviews. We value providers’ time in providing feedback and are encouraged by the positive responses. Please be assured that we review all feedback carefully. Constructive input helps us continuously improve how we deliver our reviews. The survey results informed us that 30% of providers needed help from their review officer to understand what documents to submit throughout the review. In terms of the type of assistance required providers mentioned the type of documentation and evidence needed, how to upload documents and clarification on excluded items. This feedback has informed our current Program Assurance Review number six on payment validation.

Back to Jen.

Jennifer Young:

The Department is committed to assuring HCP Program integrity. Depending on whether the matter is an assurance review concern, a complaint or a fraud matter this slide provides relevant contact details for each situation. If providers and care recipients have concerns about the Department’s Assurance Reviews or if they wish to provide intelligence for program assurance purposes they can email the Department via our shared HCP inbox displayed on the screen. Anyone can contact the Commission if they have any concerns about a provider or the care they receive from an Australian Government funded aged care service. Contact can be made via the displayed hotline or by submitting a complaint via the email address provided. Anyone wishing to report concerns relating to the potential fraudulent behaviour of an aged care provider can do so anonymously if preferred by submitting information through the Department’s fraud reporting channels as also displayed on this slide. The Department’s website also provides specific forms for completion to report suspected fraud or corruption.

As mentioned before in this presentation through our reviews we are keen to support continuous improvement of the selected providers but also the broader sector. The Department will continue to engage with the broader HCP sector through our dedicated Community of Practice otherwise known as CoP. It is an online platform supporting providers to engage with each other and the Department, share program knowledge, best practices and Program Assurance Review updates. Throughout this review regular posts were provided updating the sector on the progress and various findings. These not only supported participating providers but were an opportunity to educate all providers on areas the review team were seeing a number of providers have issues. This practice has been replicated in our current review of pricing transparency of My Aged Care.

Providers have been using the platform to seek excluded items clarifications. There are now approximately 5,200 registered users. 96% of the top 100 approved providers, that is providers with the highest number of care recipients, and 73% of all approved HCP providers are registered on the platform. All HCP providers are encouraged to join. Please note the link provided on this screen.

In conclusion we hope through this webinar and our review report the review team has demonstrated the benefits of closely working with providers to support improved understanding of program requirements and continual improvement. The significant level of positive engagement by most reviewed providers demonstrates they valued the opportunities offered by the review to closely examine and improve their understanding of HCP guidance and their associated organisational procedures. The review team again thanks the 103 providers who participated in this review. We now welcome review relevant questions. Alternatively please submit questions via our inbox as displayed on this concluding slide.

I will now hand over to Chamandeep for final comments.

Chamandeep Chehl:

Thanks Sue and Jen. Just before we go to the question and answer session I just wanted to give a plug to the latest sector pulse survey which is now open. We encourage everyone to please complete the survey and provide your feedback. You can access the survey using the URL link or the QR code on the slide. So if you could find time to do that that would be very valuable.

With that I’ll now welcome Mark to join me on the question and answer panel. Unfortunately due to unavoidable circumstances Rachel Blackwood who’s the Assistant Secretary of the Home Care Packages Program could not join us today. We’ll try and answer as many of the questions we can ourselves but otherwise we will have to take them on notice. So as I said in my opening statement the question and answer session will focus on review related questions. All other questions where possible will be answered through the responses we post online after this presentation over coming days. This means we won’t be answering questions on individual care recipient exclusions or matters outside of the review, for example related to Support at Home. So any questions that you do put in or have put in that are out of scope won’t be showing up on the screen in case you’re wondering. But we will make note of those and try and answer as many of those as we can outside of this webinar.

With that let’s go to – I’m going from the bottom up just because I think the first question is broad enough plus I can answer it and then give time for Mark and Jen who’s also on the panel I forgot to mention – time to kind of catch their breath and start answering questions. So the first one we have is:

Q:        Will the Department be increasing its audits of exclusions? Will the Department be requesting refunds for items they deem have been wrongly included? If so who will they be requesting the refund from? The client or the provider?

So in terms of this one at this stage we’re not proposing to do any more Program Assurance Reviews for the Home Care Packages Program once we finish our reviews five and six which are currently underway. And that’s for obvious reasons. Because Support at Home is coming. But we will obviously conduct Program Assurance Reviews and activities for Support at Home. So we certainly won’t be going away. 

Just to clarify that question around who’s accountable, it’s providers who are accountable for ensuring correct use of program subsidy. The Aged Care Quality and Safety Commission essentially as the national regulator is responsible for monitoring providers’ compliance with excluded service provisions of the legislation and obviously then engaging with providers to address the issues that arise. In the meantime if you have any questions about inclusions, exclusions for the program you will still continue to have access to the Community of Practice. There’s also obviously we mentioned the updated Provider Manual and there’s also a fact sheet on inclusions and exclusions. And if you have any concerns about fraudulent activity we actively encourage you – if you see something say something is kind of the line that we use internally and I think it speaks really well to if you’re in doubt please do raise it. Mention it to somebody. And there’s a variety of avenues for you to report this and they were in the presentation slides as well.

So with that I might go to another question. So in terms of the refund sorry it’s implied in there that our current review didn’t have it in scope and it’s really the Commission as the national regulator kind of monitoring compliance related activities under the legislation. So we’ve got another question maybe. I think another good one. 

Q:        The HCP Operational Manual is a guideline. Are the exclusions and inclusions for HCP Guidelines set in stone?

Mark did you want to have a go at this one?

Mark Rummans:

Sure. Thanks Chamandeep and good afternoon everyone. The Quality of Care Principles list what can and cannot be funded under the programs. Some items are strictly excluded as they are not aligned to the intent and scope of the program. To assist providers in this space where an item isn’t listed in the Quality and Care Principles we really encourage providers to use the inclusions and exclusions framework at Appendix C of the Provider Manual as it really does help providers and support them in their decision making. And it also helps them to communicate those decisions and work with care recipients around those decisions. And this is especially important as it really enables a person-centred based approach to care planning and supports a balance between assessed care needs, care goals and individual preferences for consumers, and considers also things like their financial position, cultural diversity and their location. The Manual also includes a number of case studies to assist providers as well, to give some practical examples of how to apply the decision making inclusions and exclusions framework. Thanks Chamandeep.

Chamandeep Chehl:

Thanks Mark. And I might add to that. I mean in our review reports as is evident hopefully through this report as much as possible we do clearly link to the requirement that is in the sub‑legislation for example. So we’ll refer to the Quality of Care Principles or the User Rights Principles and kind of interpret what the requirement is and then obviously go to the manual and any public facing information that the providers also have at their disposal. And we genuinely mean that we kind of walk in the shoes of providers as much as possible to make sure that there is clarity around that and if not we work with the program area to provide clarity through the report itself but also it then follows on usually in the next update of the manual or the FAQs as needed. So the Manual is a guidance document but it is based on legislation basically in terms of its requirements.

I think a related question so flows on well.

Q:        How do we support providers to be empowered to support clients and not be so risk averse?

Mark since you answered the previous one do you want to have a go at this? Otherwise I’m more than happy to have a crack at it.

Mark Rummans:

Yeah. Sure. Look we know that these decisions are sometimes difficult for providers and obviously also for consumers. So we do understand it’s not always black and white which is again why we encourage people to really explore the Manual and the tools available. But when you do have concerns you can email the Department through the direct your enquiries inbox. As both Jen and Sue mentioned in the presentation and Chamandeep has also flagged we are seeing a lot of providers using the Community of Practice to raise questions around inclusions and exclusions and the fantastic thing we’re seeing is other providers jumping in and assisting their fellow providers in understanding and answering those questions before the Department also then provides a response confirming the Department’s position.

There’s also a number of aged care newsletters and alerts, social media posts, web updates and webinars. There’s a huge number of updated web pages on the Department’s website at the moment that really does assist providers not only with inclusions and exclusions but across the program and the requirements expected of providers. And obviously too we really encourage providers to network with each other and obviously take advantage of their peak bodies and connect with those, and also our state office colleagues who are obviously located in each of the capital cities across Australia.

Thanks Chamandeep.

Chamandeep Chehl:

Thanks Mark. Let’s now get into – I’ll keep going in the order because there is a bit of mixture in those questions anyway. So this is probably more for the program area so let’s have a crack at it. This is about oxygen cylinders and we didn’t make a decision as part of our review on these sort of items that were clinical in nature. So the question is:

Q:        If the client is receiving an oxygen supplement I assume oxygen cylinders would be a permitted expense. Can you please clarify?

Do you want to have a crack at that one? And then I’ll go to Jen I promise.

Mark Rummans:

Yeah. So look as noted in our report given the types of documentation we requested from providers in relation to this review it did not include information and evidence in relation to clinical decision making. The review team deliberately did not assess items like oxygen cylinders. And obviously while it makes sense that if someone is approved for the oxygen supplement that they would receive oxygen, we do remind providers that some consumers may already be receiving oxygen cylinders through other Government funded programs. If that’s the case the Home Care Package Program cannot be used to fund the oxygen cylinder, as with other purchases where the Government provides funding through another mechanism, the Home Care Package Program shouldn’t be used for that. So we just ask to make sure that you check before you start using Home Care Package funds that they’re not receiving it through another Government program.

And we also encourage people that if you think that any of your consumers should or could qualify for the oxygen supplement to please apply for that supplement.

Chamandeep Chehl:

Great. Thanks Mark. All right Jen.

Q:        Can you please provide examples of appropriate and inappropriate purchases of iPads, iPhones, etcetera?

 Jennifer Young:

Yeah. Thank you Chamandeep. So as noted earlier in the presentation and also in the summary report this category of exclusions was one that we found was fairly common across multiple providers. So to clarify the legislation, particularly the Quality of Care Principles legislation, does list items such as all electronic devices rather, so laptops, mobile phones, iPads for example. These are all listed as specified exclusions in that legislation. And this is because they are considered to be items that all individuals must pay for themselves throughout their life reqardless of age.

Further to that in the guidance material as well there are particular exceptions to those circumstances or to those exclusions to help older people communicate with their providers, family, carers and social groups under very particular circumstances. Some of those include circumstances related to homelessness, medication management and also social inclusion purposes. Now that particular last one is in exceptional circumstances, for example during prolonged pandemic lockdowns. So I would encourage you to refer to the guidance material available on our website just to help further clarify where those exceptions can be applied. Thanks Chamandeep.

Chamandeep Chehl:

Thank you. Okay. I’m going to one that probably will be of interest. So I’m now going to go a bit random through the questions rather than in a particular order. 

Q:         Why are rideshare services an excluded item?

Mark do you want to have a crack at that?

Mark Rummans:

Sure. Rideshares are currently excluded under the HCP Program as we described in the report. The decision to exclude rideshares from the program was taken as the Department could not be satisfied that rideshare services aligned with the provider obligations under the Accountability Principles in relation to subcontracted services. With the commencement of the new Aged Care Act and the introduction of Support at Home on 1 July 2025 rideshare will be included in the service list for transport options. As with other third party services the provider will remain responsible for meeting all regulatory responsibilities including ensuring that all personnel for subcontracted services had met suitability requirements, for example police checks and other suitable qualifications, as well as all other obligations under the legislation.

For further information on third party services please go to the Department’s website. There’s a detailed web page specifically designated to third parties.

Chamandeep Chehl:

Thank you Mark. Jen maybe I’ll go to you next. But I can see a few have been upvoted so Mark putting you on notice we’ll come back on general cleaning and gardening. But for now Jen:

Q:        In terms of monthly statements what are providers’ obligations when it comes to monthly statements?

Now you kind of covered this a little bit in the presentation but maybe it wouldn’t hurt reiterating it and then I’ll go to Mark. Thanks.

Jennifer Young:

Yeah. I would agree Chamandeep. It is something worth reiterating. And again referring to some of the topics that we did cover or the content that we did cover in the presentation monthly statements and some of the issues that we found have been a sustained issue that we have seen in our Program Assurance Reviews. We do have some information and guidance on our website in terms of including a better practice monthly statement template and this is available for all providers. And we do strongly encourage providers to use this template. So this particular template will help improve the quality of your HCP statements and this will make it easier for care recipients to understand and make those informed choices about their HCP funded care and services. And really to put it in simple terms providers must itemise the care and services that you provide to a care recipient each month including how much you charged for each of those service types and separate items.

So using the monthly statement template isn’t mandatory for providers but we do encourage providers to follow as a better practice example. So more information is available on our website and we will provide a specific link to the monthly statement template in the information that’s published straight after this webinar.

Chamandeep Chehl:

Thanks Jen. And as we said in the presentation because we’ve been doing reviews for a while and most reviews require us to look at monthly statements we’ve looked at at least around 11,000 monthly statements. So this is not coming just based on this particular review experience. It’s based on a whole heap of experience before this as well. And a central kind of pillar of the Home Care Packages Program is certainly consumer directed care and consumer choice and control should be at the centre of it. And to make informed choices really you need a meaningful monthly statement which is why this is a finding we’ve belaboured in this report as well because it is something we are quite concerned about I guess from a program assurance point of view but certainly from a program management point of view.

Mark you get a couple of ones now. One is about clarification around spring cleaning.

Q:        General cleaning is allowed but what about once a year tasks such as cleaning out the fridge, microwave, oven, windows, etcetera?

Mark Rummans:

Thanks Chamandeep. The same principles that apply to general cleaning, things like dusting, vacuuming, mopping, making beds, ironing, laundry, apply for the spring clean as well if this was something the care recipient was able to do themselves previously and there’s obviously a risk to them undertaking those tasks like cleaning out their fridge for whatever reason or the microwave. Windows are a little bit more complex in the sense that not all care recipients would have cleaned their windows before particularly if they live in multi-storey dwellings and things. So again you need to use the principles of is this something that (a) will help maintain the care recipients safely living at home and (b) were they also able to do and undertake these tasks previously themselves. So using those as your consideration in and around some of those other things that may not be a weekly cleaning task but more once a year or twice yearly or quarterly and the like.

Chamandeep Chehl:

Thank you. And another one that’s getting voted up. Gardening.

Q:         What can and cannot be included?

Mark Rummans:

So gardening again similar things around was the care recipient previously able to do these things or the average person able to do these things. So again basic things like mowing the lawns, some essential pruning where those pruning of the bushes that block essential pathways for the care recipient to enter or exit their home or to their yard. We’re not looking at more extensive gardening and definitely not looking at beautification. So for example if a property has a large set of hedges that run around the property that would be at the cost of the care recipient because it’s not about maintaining their safety or their access. It’s about the beautification. Same with large properties and the like. Obviously we wouldn’t be mowing the lawns or maintaining a large rural property. What we’re looking at doing is maintaining the safety of the immediate proximity of the house to allow safe access to the house itself. And obviously we know a lot of people like to access their front and back yards as well so safe access to those yards as well.

Chamandeep Chehl:

Thank you. For others who are listening obviously we’ve got a Community of Practice that really has morphed into a program Community of Practice. It started as a Program Assurance Reviews Community of Practice. Reason why I’m mentioning it is that is the forum to ask these sort of questions as well. So just because you can’t get in now or we don’t get to all the questions is not the end of it. 

There is one Mark around:

Q:        Please could a discussion occur and examples be provided on when home maintenance can be paid through the package when the person did tasks themselves that is most likely to be out of the norm.

Is that something you want to have a crack at?

Mark Rummans:

Yeah. Sure. So again we’re looking at the average person here. And so if the average person who wasn’t a qualified tradesperson could undertake the task previously then it can generally be covered by the Home Care Package. So for example changing lightbulbs, installing and fitting emergency alarms, excluding smoke alarms, changing a washer, installation of easy tap access, and potentially repairing some flooring where there’s a trip hazard. But more extensive work that would normally be undertaken by say for example an electrician or a plumber or other qualified tradespeople like installation of goods, replacing faulty switches or rewiring whole houses, extensive plumbing work, all of those types of things, including things like pool and spa maintenance, they are all excluded under the program. And we understand obviously that some people may have formerly been a plumber or electrician so yes they could have done those things themselves. But the principle base of the program is not set for those individuals. It’s set for the average person. So a good delineation is as I said would the average person who wasn’t a tradesperson be able to undertake those tasks themselves. Even acknowledging that sometimes there may be a safety issue about but it is still a matter for the household to come up with the funds to cover those costs where they were generally being covered at any other point in their lifetime for those things.

Chamandeep Chehl:

Great. Thanks Mark. I think one – I can’t tell if it’s been voted on but I think it might be of interest to a few people.

Q:         Are family members able to be carers under the Home Care Packages Program?

Mark Rummans:

Did you want me to jump in on that one Chamandeep?

Chamandeep Chehl:

Go for it. I’m glad you’re here.

Mark Rummans:

Look we know that this has been a difficult one and this has been one of I think the success stories too from this review in the sense of tightening some of the understanding and guidance. Because a number of providers during this review did say that they had misinterpreted their understanding of when or if a family member or a friend can be used to support a care recipient and be paid through the Home Care Package. So it basically raises a really significant probity risk which is why in principle family and friends as carers paid for under the package is an exclusion. It really has to meet these five criteria and that is there is a thin market as far as providers, and by thin market we’re looking at care recipients who are living in Modified Monash Model or MMM regions 4 to 7. The family member must be appropriately qualified. The family member cannot live with the care recipient. The care recipient needs to be of culturally and linguistically diverse or Aboriginal and Torres Strait Islander background. And the family or friend cannot be receiving the carer’s payment. So all five of those criteria need to be met and demonstrated for even a consideration of a family or friend to be used under the package.

Chamandeep Chehl:

Fabulous. I think we can squeeze in one or two more Mark. So there’s one about:

Q:        In respect of medication, vitamins and supplements can you clarify what can or cannot be included?

Mark Rummans:

Sure. And look we understand, and particularly the cost of living pressures people are under, that PBS medication and non-PBS medication can add up. But this is also why the PBS safety net scheme is to protect against high costs. State and territory governments also help with the cost of running public hospitals which can offer help including with the cost of medicines that patients can’t afford. If there are no other affordable ways for care recipients to get the medicines they need their doctor can apply to the Drug and Therapeutics Committee of a local hospital to help with the costs as well. We do encourage also people to shop around where there are multiple pharmacies because different pharmacies do charge different prices particularly for non-PBS medications. So it is worth having a look around. And potentially if a care recipient has private health insurance some of these may also be covered through those.

We do want to reiterate, because it’s something that has been published for a while in the guidance, but we still saw quite a number of people including vitamins and supplements that are classified as medicines, things like fish oil and fibre powder and magnesium. These are excluded items. But we did see a significant number of these still being purchased with package funds. Where food is allowed is for enteral feeding which has also been clear for a number of years. But the Department has updated its guidance over the last 12 to 18 months to also include items under the Australian and New Zealand Food Standards particularly standard 2.9.5 and in some cases 2.9.3. I’m not going to go through all of those now given the timeframe but there’s a great list and really good explanation of those in Chapter 9 of the Home Care Package Manual and really encourage providers who’ve got questions in that space to look at the manual and go through that advice.

Chamandeep Chehl:

Great. Thank you Mark. Look I think we’ll stop there just because we do also – I can see numbers are dropping and we really do want people to please complete a short survey to help us improve our webinars. So there is a QR code showing up on your screen or you can follow the link. And please do do the survey. It takes about a minute – and thank you for all the claps that we’re seeing – to answer three short questions. 

So we’re going to conclude our presentation now. Please note we’ll have a recording of this on our website in a few days’ time. And thank you so much for finding the time during what is a very, very busy time in aged care to come join us for this webinar. So thank you all and thanks team.

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