Standard 8 requirements

With the new Aged Care Quality Standards around the corner, clinical governance must be core and integrated into all governing body risk appetite and risk management plans.

Standard 8 of the Aged Care Quality Standards (ACQS) is a game changer for managers of residential and home care operators (providers), because it will “hold the governing body accountable for the organisation’s compliance with the Aged Care Quality Standards, 2018”.

The Organisation Statement could not be clearer on the responsibilities of boards: “The governing body is accountable for the delivery of safe and quality care and services”.

While providing oversight on the strategic plan, property developments and financial outcomes have been governance 101 for boards of providers, oversight on quality and compliance has usually been seen as the responsibility of management from July 2019 that will change.

Quality and compliance have always been mission-critical issues to providers. Failure comes at huge reputational, personal and financial cost to the organisation, the care recipients and staff. I recently traced the financial performance of a provider who was sanctioned and the cost over a three-year period was in the order of $4,000,000. There are multiple recent cases in New South Wales where providers have had to dispose of their sanctioned facilities.

The failure tolerance continuum

The failure tolerance continuum is a simple tool to help directors focus their attention on what matters.

At the extreme left are the unacceptable operational failures while at the extreme right are the acceptable, if unwelcome, operational failures. To understand your vulnerability as a provider simply place quality and compliance on this continuum. This will quickly show the risk your organisation faces. The further you are to the left, the more visibility of risks and negative events the board requires. Knowing the risk is informative, the real issue is understanding the risk and how to manage it. Regrettably, this is where many boards fail.

Triple M model

The Pride Living Triple M Model—Measure, Monitor and Motivate—can assist boards develop their risk response obligations. It consists of three key elements.

Measure. Just as there are key operational metrics such as occupancy, EBITDA per place, revenue per resident, so too, there are some key metrics that can indicate quality and compliance red flags. As with all metrics, the skill is to measure the right actions and outcomes and to combine both lead and lag measures. As a result of the recent media, you might consider measuring staff hours per resident or the distribution of staff length of service.

Monitor. Deciding on what to measure is the first step, however, unless you monitor what you measure you will not see any change. Of course, you need to know when the measurement moves from acceptable to unacceptable and set triggers for action. As we have seen in the Royal Commission into banking, the CBA’s customer satisfaction rating was high and yet customers were being treated inappropriately. This teaches us that those charged with governance need to ask what the data might not be showing.

Motivate. The third and critical M is to develop a culture of ‘If it’s not perfect improve it’. Under the existing standards all providers have a Plan for Continuous Improvement (PCI), but in a culture where negative outcomes are unacceptable, there is a risk that failures and mistakes are covered up. A culture that admits we are all human and despite our best intentions sometimes we get it wrong, encourages openness and honesty. If we treat imperfections as opportunities for improvement, we can address the issues, and build a stronger culture of quality and compliance.

This article was originally published for LASA’s Fusion Magazine 2018 Summer Edition

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