Infection Control Spot Checks in Residential Aged Care: What Providers Need to Know

The Aged Care Quality and Safety Commission (ACQSC) is stepping up its program of infection control spot checks of residential aged care homes.

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Responding to Coronavirus: What are Aged Care Providers Required to Do?

Government warnings have been issued, emergency response plans have been drafted, resources have been provided, the World Health Organisation has declared a Public Health Emergency of International Concern, and the shops are running out of hand sanitiser. Coronavirus (COVID-19) has become a very big deal.

The residential aged care sector has been singled out for special attention, receiving resources from the Aged Care Quality and Safety Commission (ACQSC) and the Department of Health as well as a letter from Australia’s Chief Medical Officer.

Much of this information amounts to reminders about best-practices for infection control. But have there been any changes to laws, standards or ACQSC assessment processes? What are residential aged care providers actually required to do in response to the threat of COVID-19?


Are There Any Specific “Coronavirus Requirements” That Providers Must Follow?

Yes. Special restrictions apply to residential care workers and to residents and visitors.


Restrictions on Staff

According to the Department of Health, residential care staff can not go to work if they have:

  • left, or transited through a “high risk country” that requires isolation in the last 14 days from leaving that country
  • been in close contact with a confirmed case of coronavirus in the last 14 days (they must isolate themselves for 14 days after the date of last contact with the confirmed case).

The situation is changing quickly, but as at 6 March 2020, the advice from the Department of Health is that the “high risk countries” are:

  • Mainland China
  • Iran
  • Italy
  • Republic of Korea

For more information, see the Department of Health’s information sheet on health care and residential care workers and the ACQSC’s resources.


Restrictions on Residents and Visitors

According to the Department of Health, residents and their friends and family members must isolate themselves if:

  • they have left, or transited through, mainland China or Iran* in the last 14 days (they must isolate themselves for 14 days from the date of leaving mainland China/Iran)
  • they have been in close contact with a confirmed case of coronavirus (they must isolate themselves for 14 days from the date of last contact with the confirmed case).

For residents, isolation means you are placed in a single room away from other residents and not allowed to see visitors. For friends and family members, isolation means staying at home.

For more information, see the Department of Health’s information sheet for residents of residential care services.

*At this stage (6 March 2020), the fact sheet for residents refers only to China and Iran, rather than all “high risk countries”. This is probably because the situation is changing quickly, and the residents’ fact sheet hasn’t been updated yet. Aged care providers should err on the side of caution and apply the isolation restrictions to residents and visitors who have visited any of the “high risk countries”, rather than just China and Iran.


Are There Any General Requirements That Apply to the Coronavirus Situation?

Yes. There are two main requirements that residential aged care providers must address: infection control and emergency management.


Infection Control

In his letter to residential aged care providers, Australia’s Chief Medical Officer reiterated “the importance of infection control” and referred specifically to requirement 3(3)(g)(i) of the Aged Care Quality Standards. Under that requirement, aged care providers are expected to ensure “Minimisation of infection-related risks through implementing standard and transmission-based precautions to prevent and control infection.”

The Aged Care Quality Standards Guidance and Resources elaborates on what this requirement means, stating that providers are expected to:

  • assess the risk of, and take steps to prevent, detect and control the spread of infections
  • minimise the risk of transmission through infection management strategies such as isolating infectious causes or consumers
  • develop and implement an effective infection prevention and control program that is in line with national guidelines (i.e. the Australian Guidelines for the Prevention and Control of Infection in Healthcare)
  • have systems in place to ensure good handwashing practices are followed.

These are things that ACQSC Assessors can – and probably will – investigate. This means you should have documents at hand that can demonstrate the infection control systems you have in place; and you should ensure that staff are properly trained and can answer questions about infection control.


Emergency Management

In his letter, the Chief Medical Officer advised residential care providers to develop an emergency plan that considers such factors as:

  • first steps if infection is suspected or identified (e.g. seeking medical assessment, diagnosis and contact with local public health officials, if needed)
  • arrangements to ensure adequate care of the infected individual (e.g. staffing, isolation/quarantine within the facility, medical care, further liaison with public health officials)
  • protection measures for other residents, visitors and staff
  • notification advice to families, carers and relevant authorities.

Are emergency management plans required under the Aged Care Quality Standards? Not explicitly, but Standard 8(3)(d)(i) does require providers to have effective risk management systems and practices in place to manage high-impact risks. An ACQSC Assessor might give you a “Not Met” to this requirement if they discover that you have no plan for managing an outbreak of COVID-19.

For guidance on how to develop an emergency management plan, see the Department of Health’s Australian Health Sector Emergency Response Plan for Novel Coronavirus.


Other Factors to Consider

As if the situation weren’t complicated enough, there are a few more things you should consider when responding to the threat of COVID-19:

  • Aged Care Quality Standard 1, “Consumer Dignity and Choice” is a foundation Standard that must be considered as part of everything you do. This means that you must develop your infection control and emergency management plans in consultation with consumers. And remember to keep records of these consultations so you can show them to the ACQSC Assessors.
  • Similarly, Aged Care Quality Standards 1, 6 and 8 require you to keep consumers and their representatives as well as staff and external contractors informed about the COVID-19 situation and what you are doing in response. This is the perfect context in which to practice the principles of Open Disclosure. For more information see our previous article The Aged Care ‘Open Disclosure’ Process Explained in Five Points.
  • On top of the general requirements under the Aged Care Quality Standards, you could be subject to a specific direction from the ACQSC. If the ACQSC plans to issue you a direction, it will first inform you in writing. For more information see the ACQSC’s recently issued fact sheet “What is a Direction?”

Finally, remember that this is a rapidly changing area, so check out the Department of Health’s health alert regularly to stay on top of the latest developments.

For more information on Coronavirus, you can ring the Coronavirus Health Information Line on 1800 020 080.

Mark Bryan
Mark is a Legal Research Consultant at CompliSpace and the editor for 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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