Chapter 7
Aged Care
7.1 This Chapter considers the terms of reference dealing with the scope
and effectiveness of the proposed taxation arrangements on aged care services.
7.2 Aged care services include residential care, which includes both
nursing home and hostel care, and community based care. Community based
services include meals on wheels, respite care, day therapy centres, home
maintenance and transport. Most of these services are primarily funded
either by the Commonwealth, or jointly by the Commonwealth and the relevant
State or Territory Government, generally with some form of partial payment
by the user.
7.3 Aged care services may be provided by charitable, private sector,
or government organisations. Under the legislation most aged care services
will be GST-free.
7.4 In the Government's document Tax Reform: not a new tax,
a new tax system it was stated that:
Health care provided at hospitals, nursing homes, hostels and similar
establishments will be GST-free as will nursing care services supplied
to patients at home. The concession will extend to accommodation,
drugs, dressings and meals supplied to patients or nursing home residents
in the course of their treatment or care. Supplies of items not related
to health care…will be taxable in the normal manner. [1]
7.5 The Vos Committee made a number of recommendations in the area of
services for the aged as they relate to residential and community care,
all of which were subsequently accepted by the Government and incorporated
into the legislation. [2]
Compliance costs/cash – flow effects of a GST
7.6 Providers of aged care services emphasised that a very significant
impact of a GST will be the substantial compliance and administration
costs. While the Government has identified a $500 million assistance package,
several organisations were concerned that this package would be inadequate.
[3] Uniting Community Services Australia (UCSA)
stated that `all registered non-profit [organisations] will have to put
in place administrative systems to handle the administrative burden associated
with claiming of input-tax credits. Essentially the organisation is acting
as a tax agent of government and even though the organisation will be
rebated for the GST paid, it will have to carry the compliance costs in
the process'. [4]
7.7 Aged Care Australia (ACA) argued that the GST-free status of many
aged and community care services will not eliminate the associated administrative
and cost implications –`charities will still need to account for
GST paid on GST-free and input taxed goods and services, even though no
GST is actually collected by the Government as a result. This is inefficient
use of charities' resources and would be better spent on the purposes
for which they have been established'. [5]
7.8 The Australian Catholic Health Care Association (ACHCA) commissioned
Arthur Andersen to analyse the economic impact of the tax reform package
on the Catholic health and aged care sector, which is the largest non-government
provider of health and aged care services in Australia.
Threatens Viability
ACHCA stated that `the cumulative effects of the tax changes seriously
threaten the viability of existing services and the capacity of the
sector to deliver the same level, scope and quality of care into the
future'.
Source: Submission No.683, p.3, ACHCA.
ACHCA stated that `the impact of the indirect tax changes on the Catholic
health care sector will be substantial especially in the first year'.
- the Government estimated that the cost of the health care sector
as a whole would fall by 1.7 per cent.
- ACHCA estimated that the Catholic health and aged care sector is
likely to be almost 2.5 per cent a year worse off on an on going basis
and about 4 per cent worse off in the first year.
- ACHCA stated that `this is substantially different to the 1.7 per
cent decrease in costs that the Government has been expecting'.
Source: Arthur Andersen study, p.iii, in Submission No.683A, ACHCA.
7.9 In summary, the study found the following impact on the Catholic
health care sector:
- The indirect tax changes alone will add $36-$56 million to costs of
the sector in the first year and on-going annual additional costs of
about $5 million. Moreover, the first year cost will be repeated in
later years because of computer hardware and software costs.
- It is unlikely that a substantial proportion of cost savings generated
by the removal of embedded taxes will be passed on to the sector –
a realistic outcome would be 25 per cent of those savings, in which
case the sector could gain savings in the order of $1.8 million per
annum, representing 0.091 per cent of total costs and 0.456 per cent
of purchases.
- The sector will experience additional costs associated with the introduction
of a GST on purchases and sale of motor vehicles. The estimated additional
cost associated with this component of the tax package is approximately
$2,168,640 per annum.
- The costs of some purchases, notably those goods where the sector
is the final point of sale, may increase – this will be the case
where goods have previously been purchased WST-free by the not for profit
sector and the same exemption does not apply to other organisations.
Given that there will be one price for all purchases once WST is abolished,
it is possible that this price will be higher than currently paid by
the not for profit sector. This could occur where most but not all of
the savings from the removal of WST is passed on to purchasers.
- There will be significant additional compliance costs on the sector
that more than offset any cost savings that might otherwise be captured
due to the removal of embedded taxes on purchases.
- There may be some additional cost savings attributable to capital
expenditure items, however, as annual capital expenditure comprises
only a small proportion of actual capital stock, the cost savings will
be small in total.
- Excluding up-front compliance costs but taking into account:
- 25 percent savings from the removal of embedded taxes;
- additional motor vehicle costs;
- 10 per cent of direct WST savings being retained by suppliers
(ie. 90 per cent of savings being passed on);
- on-going compliance and administration costs; and
- additional costs on items for which leakage of GST credits may
occur, and costs associated with financing GST payments,
- the on-going annual cost to the sector is estimated to be in the order
of $4.9 million. This represents approximately 0.245 per cent of
total sector costs, and 1.225 per cent of purchases.
- There will be an estimated 1.8-2.8 per cent addition to total costs
of the sector in the first year and 0.245 per cent addition to total
costs in the second and third years . [6]
Addressing compliance cost issues
7.10 Issues related to compliance costs were raised in evidence to the
Committee. Some organisations, including ACA and the Church and Charitable
Private Hospitals Association (CCPHA), suggested that not for profit organisations
should be exempt from the GST. [7] ACA noted
that this could be done by way of a GST exemption certificate which would
mean that no GST would be payable on supplies to or by not-for-profit
organisations, in much the same way as the current sales tax exemption
works. ACA noted that this would `obviate the need for inefficient administrative
churning whereby GST is paid and then claimed back as an input credit'.
[8] ACHCA also noted that a system of exemption
would alleviate the cashflow problems associated with financing the GST
and the systems and administrative costs of identifying and claiming a
refund of GST paid. [9]
7.11 Other submissions noted that if such bodies were not exempted from
the GST, that they be fully compensated by the Government for the administration
and compliance costs arising from the GST. [10]
ACA stated that special funding arrangements will be required to fund
the associated administrative and compliance costs and to ensure that
negative cash flow implications are averted. [11]
7.12 Evidence suggested that increasing administrative and compliance
costs will also divert the resources of the sector from its primary purpose
of providing quality care to the community. CCPHA stated the services
of church and charitable hospitals `will either have to be limited or
will become more expensive'. [12]
7.13 The Committee believes that the administrative and compliance costs
associated with the new tax system will impose a significantly onerous
burden on the not-for-profit aged care sector and that these concerns
need to be addressed.
Residential care
7.14 Under the A New Tax System (Goods and Services Tax) Bill 1998 residential
care, specified under the Quality of Care Principles, and for which a
residential care subsidy is payable under the Aged Care Act 1997
is GST-free (Subsection 38-25(1) of the Bill). [13]
7.15 Residential care is defined in the Aged Care Act to include personal
care and/or nursing care provided to a person in a facility in which the
person is also provided with accommodation, appropriate staffing, meals,
cleaning, furniture and equipment. The GST-free status will not apply
to services that are not provided as a matter of course to residents,
such as television hire, hairdressing and clothing. DHAC stated that the
`vast majority' of residential care facilities which are providing nursing
home type care are funded through the Aged Care Act. Residential
care under the Bill refers to care for both aged and disabled people,
including respite care.
7.16 ACA and UCSA stated that a deficiency of the Bill is that GST-free
status is not determined by the nature of the service or by the care recipient's
assessed need for the service but by whether or not any government funding
is payable in respect of the supply of the service. [14]
ACA argued that the proposed arrangements are inequitable, as they will
mean that care recipients in relatively similar financial positions will
be treated differently. [15]
7.17 ACA also pointed to certain anomalies arising from these provisions.
A small proportion of care recipients do not receive residential care
subsidy on a regular basis due to fluctuations in their income and/or
the impact of the income test. Service providers will have to track any
changes in government subsidy payable in order to determine whether GST
is to be levied on the supply of services for particular care recipients
which will be `administratively cumbersome'. [16]
ACA also raised the issue of residential care patients classified as Category
8 residents according to the Resident Classification Scale. These residents
do not receive any government subsidy and hence would be required to pay
GST on the services they receive. [17] The
Department of Health and Aged Care (DHAC), however, advised the Committee
that `the government's intention is to cover the category 8 residents
as GST free…. They are in a residential facility and they are categorised
under the Commonwealth Aged Care Act, so the intention is that they should
be GST free'. [18] The Committee notes that
this is yet another example of poor understanding of the issues in this
area.
7.18 ACA also raised the issue of income tested fees and the GST on people
in residential care. For residents who pay income tested fees, there is
no government subsidy. ACA submitted that:
The income tested fee that the government levies on older people
in residential care can, in a number of instances, offset completely
the level of government subsidy. In fact, it can exceed it. But the
government caps it at the level of subsidy, so those people…are
not receiving a government subsidy. It is not clear that they will
be GST free. [19]
Inequitable– Australian against Australian
This means that people in similar economic circumstances in residential
care could be treated quite differently. ACA further noted that `the
income test means a small subsidy is payable for one and not the other.
You then apply GST to the full residential care fees for the person
who is not subsidised at all, and you end up with a big financial difference
between them. It could be up to $25 a week difference because of the
impost of a GST'.
Source: Committee Hansard, 3.2.99, p.212, ACA.
Case example
A small residential care subsidy of $5 is payable weekly for one resident,
whereas another resident is not eligible for any subsidy because they
have income just above the entitlement for a subsidy. The person in
respect of whom no residential care subsidy is payable will be required
to pay GST on the total fees for the service...resulting in a significant
difference in the net financial positions of the two care recipients.
Source: Submission No.364, p.22, ACA.
Treatment of similar services
7.19 Under the proposed legislation, services provided to an aged or
disabled person, by an organisation receiving Commonwealth or State or
Territory funding to provide that service, and which are similar to services
provided under the Aged Care Act, will be GST-free (Subsection 38-25(2)).
7.20 DHAC noted that there are some residential care services that are
funded through the budget processes of either Commonwealth or State/Territory
governments, rather than having a legislative base. This is often the
case when new types of services are being trialed. There is a provision
to allow the Minister for Aged Care, in a disallowable instrument, to
provide that these services are GST-free. [20]
However, that disallowable instrument has not been tabled in the Senate
and so there is confusion and uncertainty about exactly what services
will be covered.
7.21 ACA noted that while such provision is necessary to overcome problems
with the provisions `until it is exercised there remains considerable
doubt about the GST-treatment of some services, such as serviced accommodation'.
[21] Care recipients of serviced accommodation
may have the same needs and be in similar financial positions as residents
of residential care facilities and they may also receive a similar range
of services.
Case example
Trinity Place is a co-located church and retirement village run by
the Lutheran Church in South Australia. Its aged care program includes
serviced apartments established in 1985 and currently caters for 36
older people, including several married couples. Residents currently
pay an ingoing interest-free loan of $65,500 in return for a licence
to occupy an apartment. In addition, each resident pays a weekly fee
of between 75% and 85% of the basic age pension and rent assistance,
depending on the extra services they receive. Thus the financial arrangements
are similar to those required of residents in residential care facilities,
except that residential care subsidies are not paid by the Government.
Mr & Mrs G have been resident in the serviced apartments since
February 1996 and were both assessed…as being eligible for admission
to a government-subsidised hostel. They are aged 90 and 85 years respectively
and chose to live in a serviced apartment so they could stay together
after more than 50 years of marriage and enjoy a semi-independent lifestyle.
Trinity Place provides services to support them as their care needs
increase…These services are included in the weekly fees paid by
Mr & Mrs G to Trinity Place…Perversely, by avoiding the need
for government-funded assistance, Mr & Mrs G will be disadvantaged
under the proposed GST legislation. They will be required to pay GST
on their weekly fees whereas if the services were government funded
they would be GST-free. The GST on their weekly fees will be much more
than the 4% compensation proposed by the Government and will therefore
mean they are significantly worse off under the taxation reforms.
Source: Submission No.364, pp.24-25, ACA.
Daily living assistance/nursing care
7.22 The Bill also provides that services similar to those provided under
the Aged Care Act which are providing daily living assistance and/or nursing
care to individuals will be GST-free where they are determined by the
Minister for Aged Care to be providing services of a kind covered by Schedule
1 of the Quality of Care Principles (Subsection 38-25(3)).
7.23 DHAC noted that this provision provides for GST-free status for
private or community sector nursing homes or hostels that are not receiving
assistance from the Commonwealth or a State/Territory government. DHAC
stated that the decision to provide that these services will only be GST-free
following a determination by the Minister for Aged Care `was to ensure
that only the appropriate services will receive GST-free status'. [22]
7.24 ACA noted, however, that it was not clear from the Bill whether
the services which include assistance with daily living activities or
nursing services will be GST-free entirely, or only in respect of those
components of the service. [23]
Conclusion
7.25 Evidence received by the Committee indicated that that there are
several concerns expressed by aged care providers regarding the proposed
legislation as it relates to residential care services. ACA argued that
the requirement in the Bill that there be some government funding payable
in order for the supply of residential care services to be GST-free should
be deleted. [24] UCSA also stated that:
It is inappropriate to determine GST free status according to whether
the service is in receipt of government funding, rather than the nature
of the service or the recipients' assessed need for the service. This
puts at risk…those in residential care facilities who do not
receive residential care subsidy because of fluctuations in their
income. [25]
7.26 The Committee considers that the requirement for Government funding
to be paid in respect of the supply of residential care for it to be GST-free
is another example of the confusion and inequity created by this legislation.
Community care
7.27 Under the proposed legislation community care is GST-free if funding
is received by the supplier of that care under the Aged Care Act or the
Home and Community Care Act 1985 (Subsection 38-30(1)).
7.28 Community care includes a wide variety of services designed to assist
people to remain in the community and is provided to both older people
and people with a disability. The services include meals on wheels, home
help and home maintenance, respite care, day therapy centres, and nursing
and personal care. Providers of community care may be State or local governments,
non-profit community organisations, or for profit organisations. In many
cases, a small payment may be charged. This payment will be GST-free.
[26]
7.29 Evidence indicated that there are a number of anomalies and inequities
arising from the provisions as they relate to community care. Several
submissions noted that the GST-free status of community care services
is not determined by the nature of the service or the care recipient's
assessed need for the service but by whether or not any government funding
is payable for the supply of the service. [27]
At Risk – Essential Services
It is inappropriate to determine GST free status according to whether
the service is in receipt of government funding…This puts at risk
those elderly people in the community who receive essential services
for which there is no government funding.
Source: Submission No.935, p.9, UCSA.
HACC services
7.30 Several groups, including the Council on the Ageing (COTA) and ACA
also noted that the supply of government funded community care services
is grossly inadequate to meet the need for these services – with
one study concluding that there was at least a 20 per cent shortfall in
the supply of Home and Community Care (HACC) services. [28]
While services through the HACC program will be GST-free, home care services
not funded through HACC will incur a GST. [29]
COTA noted that many people are either missing out altogether on HACC
services or having their services cut back. [30]
ACA noted that people requiring community services may have to wait lengthy
periods before being able to access government funded community care services
and then the level of service may be insufficient and they may need to
complement them with privately funded services. ACA submitted that taxing
privately-funded community care services `will simply add to the inequity
these people face due to the inadequate supply of government-funded community
services'. [31]
HACC Services – Difficult to Access
ACA also noted that the use of privately-funded community care services
does not indicate the users are in a better financial situation than
recipients of government-funded services, but that HACC services are
so difficult to access. Taxing privately funded services will have significant
cost implications for the recipients of these services, the majority
of whom are pensioners who live alone, or with a carer. ACA emphasised
that these people `hold tenaciously to their independence, often with
considerable financial and other difficulties. Access to community care
services is particularly important in providing support and respite
to carers' and if they are unable to access adequate support to continue
their caregiving role or elderly people are increasingly unable to remain
living in the community, the likelihood of admission to residential
care services will increase–resulting in greater government expenditure
for these type of services.
Source: Submission No.364, p.27, ACA.
7.31 Evidence also indicated that taxing privately funded community care
services would also disadvantage people in rural and remote areas, which
are even more poorly served by government funded services than urban areas.
[32]
Daily living assistance
7.32 The Bill also provides that daily living assistance provided to
aged people or people with disabilities will be GST-free (Subsection 38-30(3)).
DHAC noted that this subsection provides that assistance with daily living
provided to individuals will be GST-free, regardless of whether the provider
receives Government funding or not. Assistance with daily living includes
assistance with dressing, personal hygiene, eating meals and mobility.
[33]
7.33 ACA noted that while these services should be GST-free, taxing particular
community care services creates problems and has the effect of implying
that some services are more important than others – `while assistance
with daily living activities is very important, there are other services
which may be equally or more important for some individuals'. [34]
Essential Services – Aged to Pay More
In some evidence concerns were raised that private home help and home
maintenance services such as housekeeping (if not provided through the
HACC program) for the elderly living in their own homes will be subject
to a GST. COTA noted that the increased costs of household services
are a concern of elderly people because they are more reliant than others
in the community on these services to maintain a house and garden.
Source: Submission No.795, p.7, COTA.
7.34 The Vos Committee rejected the proposal that privately provided
community care services should be GST-free as such services are used by
the general public as well as aged people and people with disabilities.
The Vos Committee argued that the introduction of such a scheme would
have required the establishment of an assessment mechanism to ensure that
only those people needing household help because of age or disability
could purchase them GST-free – `this was considered to be difficult
to administer and adding significantly to the cost of providing community
care'. [35] The Committee notes that this demonstrates
that the Government is more concerned with administrative `efficiency'
over equity considerations.
Flexible care
7.35 The Bill also provides that flexible care is GST-free if a Government
subsidy is payable to the supplier of that care under the Aged Care Act
(Section 38-35).
7.36 Flexible care is care provided to the elderly in a residential or
community care setting or provided through an aged care service that addresses
the needs of care recipients in alternative ways to the usual care needs
in such settings. Examples of flexible care include the care provided
in rural multipurpose services, in Aboriginal communities, and other innovative
services. These services will only be GST-free if the supplier receives
funding from the Commonwealth.
Conclusion
7.37 Evidence to the Committee indicated concerns by aged care providers
about the confusion in the legislation in relation to community care services.
Several submissions and evidence argued that the requirement in the Bill
that there be some government funding payable in order for the supply
of community care services to be GST-free should be deleted. [36]
7.38 The Committee considers that the different requirements for GST-free
status is a savage indictment of the legislation. Further, many of the
proposed tax changes in the aged care area run completely counter to Government
policy in the health area.
Retirement villages
7.39 Many aged care groups and others expressed concerns about the impact
of the legislation on residents in retirement villages. The Vos Committee
noted that while it was argued that recognition should be given, through
GST-free status, to a wide range of arrangements linking housing, including
retirement villages, to older people the Committee noted that `the Government
has already determined that retirement villages will be subject to the
GST in the same manner as other forms of long term accommodation'. [37]
7.40 Retirement villages provide a variety of accommodation services.
They may include residential care facilities approved under the Aged Care
Act. Some retirement villages also offer serviced apartments which may
offer the same mix of services as residential care facilities approved
under the Aged Care Act, although their funding arrangements differ (as
they are predominantly privately funded) and retirement village legislation
in the various States/Territories, rather than the Aged Care Act, applies
in these cases. Retirement villages also offer self-care independent living
units which are essentially a form of housing –community care services
may be provided to residents in these units as required. [38]
Under the proposed legislation retirement village recurrent fees will
attract a GST, while care services including daily living assistance will
be GST-free if the Minister determines that they are of a kind covered
by Schedule 1 of the Quality of Care Principles. [39]
7.41 The Retirement Village Association of Australia (RVAA) argued that
care services including daily living assistance services provided to residents
should be GST-free. DHAC advised the Committee that where a retirement
complex is providing nursing or daily living assistance to some of its
residents, `then the accommodation and meals provided, in addition to
the nursing and daily living assistance will be GST-free for those residents
if the Minister has determined that those services are of a kind covered
by Schedule 1 to the Quality of Care Principles'. [40]
The Department noted, however, that where an individual has chosen to
move to a retirement village, does not require nursing care or daily living
assistance, and chooses to eat at a communal dining facility rather than
eating at home or going to a restaurant, that service `will have a GST
applied'. [41]
7.42 ACA noted that that this approach will involve many practical difficulties
in determining what types of services are GST free and which are not.
GST and Retirement Complexes – Compliance Nightmare
You have a range of services that are provided to those people, starting
with emergency call systems. You have a range of support services. In
the operation of the villages we charge a composite fee. Then we get
to a point where perhaps some of those will be regarded as GST free
because they involve assistance with daily living. So we are going to
have to unbundle all that to comply or risk being non complying.
Source: Committee Hansard, 3.2.99, p.215, ACA.
7.43 RVAA also noted anomalies in this situation in that some residents
will pay GST on meals in the common dining room `while others will have
GST-free meals'. [42]
7.44 Many groups noted that the GST payable on weekly recurrent fees
which cover maintenance and other costs, such as insurance, rates, upkeep
of grounds and costs of management and administration, paid by residents
in retirement villages will impose hardship on many residents. The Combined
Pensioners and Superannuants Association of NSW and the Australian Pensioners'
and Superannuants' Federation (CPSA/APSF) argued that these costs `will
push many residents of retirement villages onto the breadline'. [43]
RVAA argued that retirement village maintenance fees should be treated
as residential rents and be GST-free with village operators input taxed.
[44]
Compensation package
7.45 Serious concerns were raised in evidence that the compensation package
for older people will be inadequate for residents in retirement villages
due to the additional costs imposed as a result of the tax package. CPSA/APSF
argued that many residents of retirement villages are on low or fixed
incomes, with many living on an age or service pension. Many have little
disposable income to meet unexpected and unbudgeted costs which will result
from the tax reform package. [45]
People in Private Sector Worse Off
Evidence to the Committee indicated that the `typical' resident of
private sector retirement village is not wealthy – over 70 per
cent are on some form of pension and most of the remainder are on fixed
incomes with their average age over 70 years. RVAA noted that with a
GST applied to maintenance and other fees the `net benefit of these
[Government] compensation measures will be less for residents of private
sector retirement villages than for the majority of older Australians
who remain in their original home'.
Source: Submission No.649, pp.2-3, RVAA.
7.46 RVAA stated that in addition to the financial impact on individual
residents, imposing a GST on retirement village maintenance fees would
discourage the needed expansion of private sector investment in this form
of retirement accommodation. This would in turn lead to increased Government
budgetary outlays on subsidies for aged care facilities such as hostels
as some retirement village residents were forced to move from privately
provided accommodation and care services to publicly funded facilities.
[46]
Conclusion
The Committee believes that residents of retirement villages will be
disadvantaged under the proposed legislation. Many anomalies in the legislation
as they relate to residents of retirement villages were referred to in
evidence. The compensation package for older people will not be adequate
for the increased costs imposed on these residents as a result of the
changes proposed.
Conclusions
7.47 The Government's tax package will lead to an increase in compliance
costs across the aged care sector. Providers will have to administer a
tax that they do not have to pay. The study commissioned by ACHCA shows
that these ongoing compliance costs will impose millions of dollars of
additional costs on the aged care sector. As providers' income in the
sector is regulated by the Commonwealth any additional costs will have
to be met by reductions in services. The quality of aged care will suffer
as a result of the additional costs imposed on the sector by the tax package.
7.48 These ongoing costs will be in addition to the large up-front costs
associated with the setting up of the systems required to administer the
tax package.
7.49 The compliance costs in the sector will be higher than most other
sectors because of the anomalies and inequities in the proposed legislation
as they relate to aged care services. The proposed legislation is confusing
and highly contradictory. Generally only residential and community care
services that receive some Government funding are GST-free. Other services,
however, such as daily living assistance provided to aged or disabled
persons is GST-free regardless of whether the provider receives Government
funding or not.
7.50 Private home help, if not provided through the HACC program, will
be subject to a GST. Many older Australians are forced to use privately
provided home help services, due to long waiting lists for government
funded HACC services. In taxing these services the GST will effectively
discourage people from remaining in their own home, when GST-free aged
care residential services are available.
7.51 Providers of services will have to negotiate through this maze of
contradictions and residents will be disadvantaged because the legislation
does not address care recipient's assessed need for the service.
7.52 As providers will be eligible for rebates on the GST they paid on
their inputs, they will constantly be owed money by the Commonwealth and
suffer cash flow costs as a result. Across the sector these costs will
be significant and, as with the additional administrative costs, will
inevitably result in a reduction in the quality of aged care services.
Footnotes
[1] Tax Reform: not a new tax, a new tax
system, p.93.
[2] Report of the Tax Consultative Committee
(Vos Report), pp.4-5; Submission No.682, p.2 (DHAC).
[3] Submission No.935, p.10 (UCSA).
[4] Submission No.935, p.10 (UCSA). See also
Submission No.668, p.3 (CCPHA); Submission No.918, p.4 (ANHECA); Submission
No.672, p.10 (Baptist Care); Committee Hansard, 3.2.99, p.212.
[5] Submission No.364, p.18 (ACA).
[6] Arthur Andersen study, pp.i-iv, cited in
Submission No.683A (ACHCA).
[7] Submission No.364, p.19 (ACA); Submission
No.668, p.4 (CCPHA).
[8] Submission No.364, pp.17-18 (ACA).
[9] Arthur Andersen study, p.14 cited in Submission
No.683A (ACHCA).
[10] Submission No.935, p.10 (UCSA) ; Submission
No.918, p.4 (ANHECA).
[11] Submission No.364, p.18 (ACA).
[12] Submission No.668, p.3 (CCPHA).
[13] Goods and services listed under the Quality
of Care Principles are broad ranging and include accommodation and maintenance
of buildings and grounds, personal care services, treatments and procedures,
recreational therapy, a limited range of furnishings, and bedding. These
services do not include additional items such as television hire and hair
dressing.
[14] Submission No.364, p.21 (ACA); Submission
No.935, p.9 (UCSA). See also Committee Hansard, 3.2.99, p.213.
[15] Submission No.364, pp.21-22 (ACA).
[16] Submission No.364, p.21 (ACA).
[17] Level 8 residents are in the `lower level'
care category, broadly equivalent to the old `hostel care category' and
do not attract a government subsidy. See Submission No.364, p.21(ACA).
[18] Committee Hansard, 2.2.99, p.54.
[19] Committee Hansard, 3.2.99, p.211.
[20] Submission No.682, p.3 (DHAC).
[21] Submission No.364, p.23 (ACA).
[22] Submission No.682, p.4 (DHAC).
[23] Submission No.364, p.22 (ACA).
[24] Submission No.364, pp.25-26 (ACA).
[25] Submission No.935, p.9 (UCSA).
[26] Submission No.682, p.4 (DHAC).
[27] Submission No.935, p.9 (USCA); Submission
No.364, p.27 (ACA).
[28] Submission No.364, p.27 (ACA). See also
Committee Hansard, 3.2.99, pp.213-14.
[29] Committee Hansard, 2.2.99, pp.
56, 59-61.
[30] Submission No.795, p.8 (COTA).
[31] Submission No.364, p.27 (ACA).
[32] Submission No.364, p.28 (ACA).
[33] Submission No.682, p.5 (DHAC).
[34] Submission No.364 p.28 (ACA).
[35] Vos Report, p.33.
[36] Submission No.364, p.29 (ACA); Submission
No.935, p.9 (UCSA).
[37] Vos Report, p.32.
[38] Submission No.364, p.23 (ACA).
[39] Committee Hansard, 3.2.99, pp.214-15.
[40] Submission No.682, p.4 (DHAC).
[41] Submission No.682, p.4 (DHAC).
[42] Submission No.649, p.2 (RVAA).
[43] Submission No.850, p.33 (CPSA/APSF). See
also Committee Hansard, 3.2.99, pp.214-15.
[44] Submission No.649, pp.,1,8 (RVAA); See
also Submission No.364, p.30 (ACA).
[45] Submission No.850, p.32 (CPSA/APSF).
[46] Submission No.649, p.6 (RVAA).