Under the Aged Care Quality and Safety Commission Rules, Aged Care Providers must always have a current written Plan for Continuous Improvement (PCI). But a PCI doesn’t have to be just another regulatory burden – it can be an opportunity. In this article we explore what a PCI is, why it matters and how you can use it to your advantage.
What is a Plan for Continuous Improvement (PCI)?
A PCI is a written plan developed by an Aged Care Provider. It sets out how the Provider will assess, monitor and improve its quality of care and services, measured against the Aged Care Quality Standards (Standards).
The Aged Care Quality and Safety Commission (ACQSC) advises that Providers can use their own form of PCI or the ACQSC’s template, but Providers using their own form should ensure it includes all the areas covered in the ACQSC’s template. You can download the ACQSC’s template here.
Why PCIs Matter – The Legal Obligation
PCIs matter because Aged Care Providers are required by law to have them. Section 62 of the Aged Care Quality and Safety Commission Rules (Rules) says that all Aged Care Providers must have a written PCI that sets out how the Provider will:
- assess the quality of care and services they provide against the Standards
- monitor and improve care and services as measured against the Standards
- address any identified areas of improvement to ensure compliance with the Standards.
You can see that the PCI is closely linked to the Standards. On top of this there is a specific requirement under Standard 8, requirement (3)(c)(ii) that says Providers must have a governance system relating to continuous improvement.
Recent Changes to the Way the ACQSC Deals with PCIs
It used to be the case that, if an ACQSC assessment team made any findings of “Not Met”, the Provider would be issued with a Timetable for Improvement (TFI). As of January 2020, however, the ACQSC is no longer required to issue a TFI and the procedure for responding to “Not Mets” has changed.
Now, if an assessment team makes a finding of “Not Met”, the Provider will be required to submit a revised PCI that explains how they will address the “Not Met” area and achieve compliance within an agreed timeframe. The ACQSC will then take a risk-based approach to determining the appropriate regulatory response, which ranges from directing providers to amend their PCI to imposing sanctions or revoking accreditation.
For more information on recent changes to the ACQSC Rules and procedures see our article: New Aged Care Commission Rules for 2020: Key Changes Providers Need to Know.
Why PCIs Matter – A Good Continuous Improvement System is Better for Everyone
PCIs matter because they empower aged care providers to address compliance challenges proactively, efficiently and sustainably. In other words, they empower aged care providers to deal with compliance systematically.
But having a system for continuous improvement is beneficial not just from a compliance point of view. It also allows time and resources to be used in the most efficient way to maximise the quality of care and services being delivered. This not only reduces the regulatory burden on Providers, it also improves the quality of care for consumers.
Continuous Improvement In Practice: The “Plan-Do-Check-Act” Model
So how do PCIs fit into a continuous improvement system and how does this all work in practice?
The ACQSC provides some answers to this question in its guide for continuous improvement. The guide sets out a four-step process known as the “Plan-Do-Check-Act” model. This model involves a cyclical process, in which each step builds on the previous step and feeds into the next. It is a well-known problem-solving technique used to improve business processes.
The PCI features in every stage of this process. It’s not only used when making the plan in step one, it’s also the place where you record the processes and outcomes of the other three steps.
1. Plan: What changes should you make and what do you think they’ll achieve?
This first step forms the foundations of the continuous improvement system. This first step involves mapping out the desired outcomes and existing systems and processes. This should allow for the identification of areas for improvement and also the development of a plan for improvement.
When making the plan, a good starting point is to look at the Standards and ask:
- What systems or processes do we have in place to meet this requirement?
- What are our desired outcomes?
- What is the best way to meet this requirement?
- What resources are being used?
- What resources do we need?
The ACQSC’s Self-Assessment tool will help you achieve this step of the process. You will also need data. This data come from other systems that you have in place, such as those you use for monitoring or gathering feedback. The data should tell you:
- where a requirement or desired outcome is not being met
- where resources are being used inefficiently
- gaps in processes or resource requirements.
If you find that you don’t have access to any useful data, this may be a sign that your feedback and monitoring systems need to be improved.
Next you can develop your plan, which should specify the:
- desired outcome
- planned action to achieve it
- methods for evaluating the success of actions, including the intervals at which evaluation is to be done.
2. Do: Implement the improvement
After developing an action plan for improvement, you need to implement it. During the planning stage you may have identified multiple areas for improvement, some requiring bigger changes than others. At the implementation stage it helps to take incremental actions on a small scale. This prevents wastage of time and resources and makes implementation more manageable.
To effectively execute this step, you need to:
- allocate the necessary resources to maximise the chances of success
- have an effective feedback and monitoring system.
3. Check: Evaluate the success of the improvement activity
After the timeframe for action is completed, you need to check whether your action plan succeeded. Success is based on whether the desired outcomes, identified in the planning stage, were met.
4. Act: Take action to standardise the process
The next step depends on the outcome of the “Check” stage. If the strategy was not successful, you need to cycle back to the planning stage to adjust your strategy.
If the strategy proved successful, you need to consider how to implement it at full scale. Resources are an important consideration. Also important, however, is ensuring that all stakeholders understand not only what needs to be done, but why. Projects work best when all team members have a common understanding and work towards a common goal.
Whether or not each action plan is successfully implemented, the outcomes should be reported to key stakeholders, including as part of your governance systems. This transparency encourages responsibility and accountability throughout the organisation. It also creates a culture of openness to critical evaluation and innovation and encourages everyone to work towards improving the quality of care and services.
Continuous improvement doesn’t end with full scale implementation of a successful strategy. Your PCI should be a living document within a dynamic system that can readily adapt to changes, whether they be the needs and preferences of the consumers or changes to the regulatory landscape.
Developing a PCI isn’t about applying a band-aid fix to meet the Standards. It’s about encouraging change in a systematic way that allows you to continue to meet the Standards over time, without the ASQSC continuously looking over your shoulder.