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New COVID-19 Vaccination Reporting Requirements for Residential Aged Care and In-Home Care

20/07/21
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In a previous article, we summarised the requirements for residential aged care providers to report weekly on the COVID-19 vaccination status of their workers. Those requirements came into effect 15 June 2021 and continue to apply.

 

In addition, the Department of Health has announced that:

  • from 13 July 2021, residential aged care providers must collect records of the COVID-19 vaccination status of residents
  • from 27 July 2021, residential aged care providers must report weekly on the COVID-19 vaccination status of their residents
  • from 1 July 2021, providers of Home Care Packages (HCP) and Short-Term Restorative Care (STRC) services in home or community settings must start keeping records of the COVID-19 vaccination status of their workers
  • from 27 July, providers of HCP and STRC services in home or community settings must report weekly on the COVID-19 vaccination status of their workers (including contractors and volunteers)
  • currently (as at 19 July 2021) HCP and STRC services are not required to keep records of their clients’ vaccination status
  • there are currently no vaccination reporting requirements for Commonwealth Home Support Programme (CHSP) and National Aboriginal and Torres Strait Islander Flexible Aged Care Program (NATSIFAC) services in home and community settings. (This is as at 19 July 2021. The Department of Health says the requirements have been “deferred” so they may apply in future).

The Department is collecting de-identified data, so you won’t have to provide names of workers or residents, just numbers.

 

 

Residential Aged Care Providers

What do I have to report?

  • Total number of residents and workers at each aged care service and, of those,
  • the number of residents and workers who have received a first dose of a COVID-19 vaccine
  • the number of residents and workers who have received all required doses of a COVID-19 vaccine (this number excludes the number of reported residents who have received a single dose only).

 

When do I have to report?

Reporting vaccination status of workers is currently mandatory and must be reported every week. Reporting vaccination status of residents is mandatory from 27 July 2021. From then on, you must report every week. This means you must collect data every week and report it every week.

 

How do I report?

Report via the My Aged Care service provider portal.

 

Who is a “resident”?

The Department of Health defines “resident” as “any individual residing in your service’s aged care facilities, including residential respite care, during the weekly reporting period.”

The definition of worker is broad and includes anyone (including volunteers) responsible for resident care, support and services for residents, maintenance or administration at a residential care facility.

 

Vaccination and disclosure of vaccination status are voluntary

Residents do not have to get COVID-19 vaccinated. Also, residents do not have to tell you whether or not they are vaccinated. However, it is likely that you will already have a record of the resident’s vaccination status.

If a resident declines to be vaccinated or to provide information on their vaccination status, you should still include them in the total number of residents at the service.

 

You do not need to record type of vaccine or when it was administered

You do not need to report information on the type of vaccine (AstraZeneca or Pfizer) the resident has received or when or where the vaccination was administered.

 

How can I arrange a COVID-19 vaccine for residents not yet vaccinated?

Contact your local Primary Health Network or general practice to organise local access to a vaccination.

 

 

HCP and STRC Services

What do I have to report?

  • Total number of workers at each aged care service and, of those,
  • the number of workers who have received a first dose of a COVID-19 vaccine
  • the number of workers who have received all required doses of a COVID-19 vaccine (this number excludes the number of reported residents who have received a single dose only).

 

When do I have to report?

Reporting vaccination status of workers is currently mandatory and must be reported every week. Reporting vaccination status of residents is mandatory from 27 July 2021. From then on, you must report every week. This means you must collect data every week and report it every week.

 

How do I report?

Report via the My Aged Care service provider portal.

 

Who is a “worker”?

According to the Department of Health, “worker” means “all staff, including volunteers and subcontractors, who access, or are reasonably likely to access, any premises where the operation or administration of the service

occurs. This includes all people in your service who deliver aged care services to people in their homes

and in the community, and who work at your business premises including office staff.”

 

Vaccination and disclosure of vaccination status are voluntary

As at 19 July 2021, COVID vaccinations are “strongly encouraged”, but this is not a legal requirement. Also, workers do not have to tell you whether or not they are vaccinated, and you should not pressure them to answer.

If a worker declines to provide information on their vaccination status, you should still include them in the total number of workers at the service.

 

Evidence of vaccination status is not required

As at 19 July 2021, workers are “strongly encouraged” to confirm their vaccination status, but this is not a legal requirement.

The Department advises that if a worker wants to show evidence of their vaccination, they can provide:

  • a vaccination certification or other evidence from a vaccine provider
  • an immunisation history statement which they can access from Medicare online or the Express Plus Medicare mobile app
  • a signed declaration
  • a record from a health practitioner.

 

How should workers be counted if they work at more than one service?

If workers (including volunteers) work across multiple organisations/services, providers should record workers against the service where they spend the most time. If a worker spends approximately the same amount of time across multiple services, you can attribute them to a single outlet so that they are only counted once.

 

What should I say to my workers?

The Department of Health encourages you to “have respectful conversations with workers on the new reporting of

aged care workforce COVID-19 vaccination status and to ensure they understand:

  • why this information is being collected, including as part of the facility’s COVID-19 preparedness and planning
  • accessing a COVID-19 vaccination and advising their employer of their vaccination status is strongly encouraged
  • the approved provider is not required to collect or store workers’ personal information in order to report on the vaccination status of the workforce
  • that any information collected and maintained by the approved provider will adhere to privacy requirements
  • the details of their personal vaccination status will not be reported to the Department of Health
  • their right to decline to provide this information without any recrimination or judgement.

You should also consider sharing with your workers this fact sheet from the Department of Health: Department of Health: Factsheet to support in-home and community aged care workers on the new reporting requirement

 

What happens if I don’t comply with the reporting requirements?

In regard to residential care providers and HCP and STRC services, the Aged Care Quality and Safety Commission (ACQSC) will monitor compliance with the reporting requirements and has power to take regulatory action if you do not comply. This may include sanctions.

 

Use these reporting requirements to your advantage

The data you will have to collect under these requirements is minimal: you only have to collect the total number of workers, and number of vaccinations. But it will still cost you time, staffing resources and effort to collect and report on this information every week. So why not get something useful out of a task you have to do anyway?

When drafting your data collection forms, consider adding a few more fields that you can fill in when talking to your workers or reviewing records. These might include:

  • Name, role and other details of the worker along with their vaccination status – this will help you to allocate vaccinated and unvaccinated workers to appropriate zones in the event of a COVID outbreak.
  • Worker status (employee, contractor, volunteer).
  • Does the worker work at any other sites? Which sites?
  • Which vaccine have they received? (AstraZeneca or Pfizer).
  • Date the vaccine(s) were received.
  • If the worker has had only one shot, when is the second shot due?
  • If the worker provided evidence of vaccination, what is the evidence?
  • Details of the worker’s consent regarding the information they have provided you.

 

When collecting information from workers make sure you adhere to privacy requirements:

  • This information must be given voluntarily and without duress.
  • Explain how you will be using this information (for example: to fulfill your duty of care to residents, and to ensure workplace health and safety for workers).
  • Explain which pieces of information are required for reporting required by government.
  • Explain the consequences of not providing the information.

 

Further resources

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About the Author

Mark Bryan

Mark is a Legal Content Consultant at CompliSpace and the editor for Aged Care Essentials (ACE). Mark has worked as a Legal Policy Officer for the Commonwealth Attorney-General’s Department and the NSW Department of Justice. He also spent three years as lead editor for the private sessions narratives team at the Royal Commission into Institutional Responses to Child Sexual Abuse. Mark holds a bachelor’s degree in Arts/Law from the Australian National University with First Class Honours in Law, a Graduate Diploma in Writing from UTS and a Graduate Certificate in Film Directing from the Australian Film Television and Radio School.

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