90 Days to Aged Care Act Readiness: Document or Get Out
The rights‑based Aged Care Act is nearing implementation. Even as commencement timing is being finalised, duties for boards, a consolidated Statement of Rights, stronger regulator powers, and sharper incident/complaints obligations are clear. Here’s how small providers can move from uncertainty to assurance in 90 days.
1) Introduction: The Countdown and the Cost of Waiting
“We’ll act when the start date is confirmed” sounds sensible—until you realise delay isn’t a pause. The regulator’s expectations, director duties, and rights‑based care principles will shape how you govern and deliver services in both residential and in‑home care. The sector is already stressed by workforce shortages and reform fatigue; waiting just concentrates risk. Your edge as a small business is speed: a board‑endorsed plan and a living compliance register can turn ambiguity into momentum.
2) Challenge: No Date Certainty, Yes Duty Certainty
Boards asked, “What can we sign off before the Rules are final?” Plenty. The core problem wasn’t the unknown date—it was the absence of a single source of truth. Without a structured register, obligations lived in emails and people’s heads, not in evidence. That invites penalties, poor compliance ratings, and governance gaps.
Solution Move #1: Stand Up a Live Compliance Register
- Map each clause in the draft Act/Rules to your policies, workflows, and evidence.
- Fields to include: requirement, risk rating, accountable owner, status, due date, proof (e.g., minutes, training logs), latest test.
- Refresh weekly; table monthly at the board.
Board Endorsement
Adopt a resolution: “Management will maintain a living register mapped to the draft Act/Rules; progress is a standing agenda item until full commencement.”
3) Challenge: Turning Rights into Daily Workflows
The Statement of Rights is not wall art. People must experience it at the point of care and contact. The gap we found: rights were stated, not operationalised.
Solution Move #2: Operationalise Consent, Choice, and Complaints
- Consent & Choice: Embed explicit, revocable consent in intake, care planning, and every change of service. Capture in your client system; timestamp and version control.
- SIRS & Complaints Triage: Define what is actually reportable; set a 2‑hour internal triage target; use decision trees to avoid under/over reporting.
- Worker Screening: Automate pre‑employment checks and recurring verifications; block shift allocation if checks lapse.
- Record‑Keeping: Standardise naming conventions; lock audit trails; retain evidence of choice and cultural preferences.
Tip:
Run a weekly “rights in action” huddle—review a de‑identified case and ask, “Where is the proof of choice and consent?”
4) Challenge: Governance Under a Stronger Regulator
With expanded powers and harsher penalties flagged, regulatory decisions can affect the compliance rating of one home—or your whole portfolio. Directors need line of sight to real evidence, not reassurance.
Solution Move #3: Board Assurance that Works
- Briefing Pack: One concise deck on director duties, regulator powers, and how the Statement of Rights maps to existing Quality Standards.
- Three Lines Clarified: Ops own controls; risk/compliance test them; board receives independent assurance.
- Evidence-First Reporting: Replace narrative with artifacts: audit samples, incident trend heatmaps, training completion by role.
Meeting Cadence
Risk committee monthly until commencement; full board quarterly with deep dives on complaints and SIRS.
5) Challenge: Chaos Without Documentation
When teams are thin and dispersed, “tribal knowledge” breaks. Remote workers can only follow what’s written, routined, and searchable.
“Document your business or get out.”
Solution Move #4: One Playbook, One Truth
- Single Source of Truth: Centralise policies, SOPs, forms, and templates; version control; link every SOP to the register item it satisfies.
- Clickable Workflows: Short, step‑by‑step checklists with screenshots beat 30‑page PDFs.
- Read‑to‑Run: Each SOP includes purpose, owner, last review date, and success criteria so remote staff can “do the next right thing.”
Micro‑metric:
Time to onboard a casual carer drops when your SOPs are obvious and testable.
6) Resolution Path: The 90‑Day Readiness Sprint
We treated reform like a product launch—time‑boxed, scoped, and measurable.
- Days 1‑10: Baseline & Plan. Build the compliance register; gap‑assess policies; publish sprint backlog and RACI; schedule board briefing.
- Days 11‑30: Rights to Workflows. Ship updated consent/choice forms, SIRS decision tree, complaints triage, worker screening automations, record‑keeping standards.
- Days 31‑60: Train & Test. Role‑based micro‑learning; tabletop incident simulations; sample audits of consent evidence and complaint resolutions.
- Days 61‑80: Assure & Fix. Internal audit on top 10 risks; remediate; retest; update the board with artifacts, not promises.
- Days 81‑90: Lock‑In. Finalise SOPs; publish a 12‑month review calendar; rehearse regulator responses; confirm director attestations.
Acceptance Criteria
- Register is complete, current, and referenced in board minutes.
- Every client file sampled shows consent and choice evidence.
- SIRS/complaints triage meets the 2‑hour target; escalation paths proven.
7) Results: Assurance You Can Show
By day 75, the board meeting sounded different.
Chair: “Show me where ‘dignity and choice’ lives in practice.”
CEO: “Here—policy link, SOP, training module, and three file samples in the register. Audit trail attached.”
Director: “And incidents?”
Quality Lead: “Triage dashboard shows ‘red to amber’ trend; two near‑miss learnings pushed into the medication SOP yesterday.”
Outcome: mock audit with zero critical non‑conformities, improved complaint resolution speed, and a board that can point to hard evidence—not hope.
8) Outro: Move First, Sleep Better
The Act’s timing may shift, but your duties are already rising. Small providers win by being organised, not oversized. In the next 48 hours: approve the register, prioritise the 90‑day sprint, and book a board briefing on director duties. Make your documentation the backbone that lets remote teams deliver rights‑based care, every shift.
Related Links:
- About the Aged Care Act (Department of Health and Aged Care)
- A new Aged Care Act: what is changing (KWM)
- Regulatory update for aged care boards and managers (Hall & Wilcox)



