·         There is industry misunderstanding of the ACFI tool

·         The Business Rules are good – Industry is complicating them in implementation.

·         There is a need for ongoing training of providers.

·         It is important that people use the user guide and don’t rely solely on training.  There needs to be
a process for communicating and updating the user guide to make sure people using right ones.

·         Use of appeals – 10 upheld

·         Medicare Claiming Issues need to be included in the submission.

 

 

ACFI REVIEW FUNDING

 

·             Organisations that are doing well under ACFI have good processes and management and resources dedicated to it.  This is an organisational responsibility.

·             There are mixed messages from providers about whether ACFI has improved funding levels.

·             It seems that funding is better overall, even in low care, but need:

o     Ongoing training

o     Importance of admission policy

·             Impact of grandparenting removal needs to be factored in.

·             The majority of the industry is underclaiming (validation data)

·             R&R not able to manage resident profile as well as metropolitan providers.

·             R&R access to training is inadequate.

·             Impact on access for consumers where providers are not accepting lower level funded clients.

·             Importance of levels (skewing of L/M & H/H – demarcation – difficulty to move from L-M-H  in ADL’s).

·             Funding attached to high behaviours not enough.

·             High needs focus for future – have to get right. 

·             Push back to Community Care.

·             Align Residential and community

o               Low assessed = $ same in Residential/Community

o               Recognise all res care = 24/7 service and CC doesn’t.

·             Med $ not enough for continence products – has been addressed and we should acknowledge it in the submission.

·             Special cases – Intellectual disability, R&R Homeless – may be needed or ACFI tweaked to support appropriately.

·             Palliative Care needs to allow retrospective claiming.

·             High cost consumables (e.g. tracheostomy care) not covered in ACFI.

 

 

ACFI REVIEW – CLINICAL CARE

 

 

·             Validation officers should only see residents where there is incongruence.

·             Approach to validation – not nit picky (e.g. diagnosis always valid).

·             Palliative care is not specific enough, ACFI needs to be better developed.

·             Where the appraisal pack is used properly, ACFI documentation is definitely required less than under the RCS.

·             Issue of links between ACFI/CIS creating some documentation issues.

·             Validations have been good in some states.

·             Post dating of evidence shouldn’t occur.

·             Medicare – some issues if move to desk top diagnosis.  The validation currently considers all diagnosis (not just 3 which Medicare system allows).  Moving to desktop validation needs to ensure all evidence is available to be considered.

 

ACFI REVIEW – SYSTEM DESIGN

 

Diagnosis List:

·         Cognitive impairment & high PAS should = diagnosis

·         Depression & Cornell & anti-depressives = diagnosis

·         Stigma attached to dementia & depression.  Impact of GP behaviour on getting diagnosis

·         It has been good to have diagnosis for depression as it is bringing the issue to the fore in residential care (not just funding)

·         Use of Cornell – training needed

·         Importance/Validity of talking to staff

·         ABI not recognised

·         Clarity of management of provisional depression diagnosis.

 

Nutrition:

• Clarity around thickening of fluid.  Should be included in willingness to eat.
• Same as Vitamising food.    Include peg feeds foods

 

Mobility:

• Physical assistance/not supervision of callipers
• Stand by/assist when person has cognitive or disease that might impact
• Link with wandering and not being able to claim - both needs to be addressed.

 

·          Personal Hygiene – no issues to raise

·          Toileting - Emptying drainage bags = physical assist

·          Continence – Forms need to be redesigned for urine/bowel charts.

 

Cognitive:

•  PAS/RUDAS/KICKA acceptable
• Mini mental excluded originally on charge grounds which may not still be issue.  
• Accepting MMSE on ACAS.
  
  

·         Wandering – see mobility point

 

 

 

 

Verbal and Physical Behaviour

• Not all behaviours covered eg. Passive aggressive
• List of behavioural symptoms is good.

 

Depression:

• Issues with use of Cornell and GP’s formalising diagnosis
• Geriatric depression scale should be allowed as evidence (easier than Cornell)

 

Medication

• Difference between low/high complex care. If you get “B” and No Q12 claim – must get low regardless.  Would assist R&R providers.
• Prep time (crushing) should be OK.
• Acknowledge no need to keep a timing record.

 

Complex Health Care

• Blood pressure at least 2 x week
• Blood glucose at least 2 x week
• Monitoring of weight/significant weight loss at least 2 x week
• Pain (4A) & (4B) massage therapist, exercise physiologists and physio assistants must be included.
• Q3 extend allied health care definitions e.g. physio assistants under direction of physio ongoing and with competence training.
• Directive – records for doing it not part of pack and shouldn’t be required.
• Q5 – 4 x day limited – Parkinsons not covered – should be no limit on number of times.
• Q6 – speech pathology directive but competency based for delivery
• Q9 – Just hepatitis/not limited to infectious
• Q12 – Chronic skin conditions – dry, frail skin should be included
• Q14 – what constitutes “end of life” care not palliative care – pain assessment not mandatory.

 

 

 

Where does it fit within the review?  Doesn’t fit. 

ANF Agenda re Ratio’s

The submission needs to be written without playing into that Agenda.

 

 

 

 

• More consistency with ACFI?
• ACAT only assess for entry into residential aged care
• ACFI then assesses but not limited to high/low care.
• Validation manages financial risk.
• Attach bond to bed licence.