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LLLB comments / feedback

Please find below some broad comments for consideration.
Why is there still a requirement to have time limited ACCRs? Either a person is approved or not
approved. It seems unnecessary. Check ACAT Guidelines as to why this is really necessary.
Should not references in the Act to a 'particular kind' of care be changed to 'care type'?
Is there going to be the provision for Sanctions for Home Care packages?
What about ACCRs that are for MPS and HACC being able to be submitted to DHS (Medicare)
and just sit there for any future use. This would save heartache especially when a person receives
care in an MPS and then transfers to a 'mainstream' aged care residential service. The service
then has to fight DHS (Medicare) to prove that there was continuity of care and allow subsidy to
be paid.
Can we have a bit more definition and explanation about Consumer Directed Care that must be
provided with all newly allocated Home Care packages via ACAR. The information on the
website is very broad.
On page 42 you mention terminology - can you please check all places in the Act and Principles
so that consistent terminology is used. Eg Care Recipient in all places instead of resident.
High Care Dependency Leave. This needs to be abolished. It is no longer appropriate. Many
services are now better placed for ageing in place than when the Act was first introduced. Also
with the availability of Transition Care it is far better for a care recipient to be provided with TC
rather than go to another service for it. We realise that a care recipient has to be admitted to a TC
service from hospital but this is usually the case with HCDL anyway where the care recipient
goes to hospital and then to the other service.
Retrospective claims - something needs to be included in the Act about there being a time limit
of 2 years for which a service can ask for the backdating of something. DHS (Medicare) ahs told
us that there is the provision for this to be longer but that it is not usually done these days. We
need legislation to support this.
Payroll Tax - this needs to be sorted out properly in the legislation. It is ambiguous. Or better
still, get rid of this altogether.
Something needs to be strengthened in respect of services with new or additional places having
to really comply with getting them operational. This applies to both residential and community
as well as flexible services but more so to community and flexible.
The mechanism for calculating the hours of service for community and flexible services needs to
be clearly formalised whether this is via the Act or provided for in the Principles.