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AWF.660.00069.0001_0001 Submission to the Royal Commission into Aged Care Quality and Safety. Aged Care Program Redesign. Services for the Future. Minimising medication-related harm across all care streams. Ward MM January 2020 Key contacts: Dr Jo die Hillen wardmm medication management Senior Research Analyst cmwardmm.com.au) Dr Na t a l ie Soulsby Head of Cl inical Development mm.com.au) Ms Fiona Rhody- Nicoll CEO - wardmm.com.au) Ms Christ ine Cussen Head of Government Relations and Market Access

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AWF.660.00069.0001_0001

Submission to the Royal Commission into Aged

Care Quality and Safety.

Aged Care Program Redesign. Services for the

Future.

Minimising

medication-related

harm across all care

streams.

Ward MM January 2020

Key contacts:

Dr Jodie Hillen

wardmm medication management

Senior Research Analyst cmwardmm.com.au)

Dr Nata lie Soulsby

Head of Cl inical Development (~ward mm.com.au)

Ms Fiona Rhody-Nicoll

CEO - wardmm.com.au)

M s Christ ine Cussen

Head of Government Relations and Market Access (~wardmm.com.au)

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Table of Contents Introduction ............. ............................ .............................. .......................... .......................... ............... 1

Key messages: ......... ............................ .......................... .... .......................... .......................... ............... 2

Question 1 .............................................................................................................................................. 2

General Comments ........................ .......................... .... .......................... .......................... ............... 2

Question 2 ......... ........... .... ...................... .... ...... ....... ........... ............... .................................................... 4

Medication Specific ....................... .............................. .......................... .......................... ............... 4

General Comments ........................ .......................... .... .......................... .......................... ............... 5

Question 3 ............................................................................................................................................. 6

General Comments ........................ .............................. .......................... .......................... ............... 6

Medication Specific ....................... .............................. .......................... .......................... ........... .... 7

Question 4 ................ ............................ .............................. .......................... .......................... ............ ... 7

Medication Specific ........................................................................................................................ 8

Question 5 .... ............ ............................ .............................. .......................... ............. .. ............... .... ... .. 10

Medication Specific ....................... .......................... .... .......................... .......................... ............. 10

Question 6 ......... ......... ...... ................................ ....... ........... ............... .................................................. 11

Medication Specific ...................................................................................................................... 11

Question 7 ................ ............................ .............................. .......................... .......................... ............. 11

Medication Specific ....................... .............................. .......................... ............. .. ............. ...... ... .. 11

Question 8 .. .............. .... ........................................... ........................................................... .............. ... 13

Medication Specific ...................................................................................................................... 13

Question 9 ................ ............................ .......................... .... .......................... .......................... ............. 13

General Comment .......................... .............................. .......................... .......................... ............. 13

Question 10 ......................................................................................................................................... 14

Medication Specific .......................................... .......................... .................................................. 14

References ... ............ ............................ .......................... .... .......................... .......................... ............. 15

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Introduction

WardMM welcomes the opportunity to comment on the Royal Commission's latest consultation

paper, 'Aged Care Services Redesign, Services for the Future.'

In November 2019, Ward MM made a submission to the Royal Commission titled 'Medication Safety and Quality in Aged Care' (WMM Submission). in response to the interim report which proposed six

solutions to improve medication management in aged care as stated below.

Six Simple Solutions:

The implementation of targeted full cycles of care through an enhanced

Residential Medication Management Review (RMMR) and Home

Medicines Review (HMR) program.

Build capacity and capability in the delivery of safe and appropriate use of

medicines at an aged care institutional level with enhanced 'time on

ground' (through enhanced QUM).

Maintain market forces by empowering aged care providers to select their

provider of medication management services.

Maintain the requirement for accredited clinical pharmacist specialist

knowledge in what is a highly nuanced and complex area of medicine -

medications and their effects in older people.

Harness data to encourage accountability and inform policy.

Invest in funding for research in aged care.

In response to the RC Interim report, the Government announced an additional $25.5 million in

funding to provide enhanced medication management models in aged care. Ward Medication

Management welcomes this boost in funding. In our response to this consultation paper, we have

focused on how enhanced medication management services can be integrated across all three

proposed aged care streams.

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Throughout this document, where relevant, we have made references to our original submission by

solution and page number. For several of the questions, we have made comments which relate more

broadly to the aged care sector.

Key messages:

• Aged care services, including enhanced medication management review services, should be

collaborative, proactive and preventative. Optimising both investment and potential savings.

• Medication management services should be available in all care streams to optimise

opportunities to mitigate unnecessary future spend and harm.

• Service delivery models should address a person's risk of medication-related harm and

provide f lexibility to accommodate changing needs as they move through care streams.

• Enhanced Quality Use of Medicines programs should address the known gaps in education

with respect to medication management services and knowledge of medication safety.

• Programs should incentivise collaboration and integration of services.

• There should be an emphasis on overall governance with transparency and accountability.

Question 1: What are your views on the principles set out on

page 4 of the consultation paper?

General Comments

Overall, the 12 principles proposed for the new Aged Care Program cover internationally recognised

criteria for delivery of quality care programs as outlined by Australia's National Health Framework:

safety, responsiveness, continuity of care, accessibility, efficiency and sustainability (1). At face value,

all 12 principles seem fair and just and address known shortfalls of the current system.

A major goal of redesigning the program is to prepare older Australians and the aged care system

to deliver quality of care in an environment of increasing demand. Missing from these 12 principles

is the concept of PROACTIVE AND PREVENTATIVE CARE. Proactive models of care can support

Australians to avoid unnecessary and avoidable use of health and social services minimising the

demand on the system over time.

We state this concept upfront to acknowledge the importance of a sustainable aged care program.

Proposal: Principle 13: The new program should deliver timely proactive and preventative care.

Of particular importance to Ward MM's area of specialism, medication management in the elderly, is

Principle 10, 'support effective interfaces with related systems, particularly health and disability'. The

principle of ensuring effective interfaces, in particular with health and disability, is to be applauded.

To enhance this Principle, consideration must be made to the alignment between different systems.

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Lack of Alignment - Unintentionally Undermining Program Objectives

A specific example which currently applies in the area of medications in the elderly:

A system of medication review has been created which aims to foster collaboration between GPs and

Accredited Clinical Pharmacists. Deliberate efforts have been made to ensure both GPs and Accredited

Clinical Pharmacists are remunerated for their involvement in the creation and review of a medication

management review (RMMR I HMR I DMMR).

These services are funded by two different bodies. The Community Pharmacy Agreement administers

the Accredited Clinical Pharmacist funding and the Medical Benefits Scheme reimburses GPs for their

collaborative role.

There are however discrepancies between the rules which govern these different pools of funding.

Although minimal, the variation in language used to describe the criteria which governs eligibility for

a medication review frequently result in individuals not receiving the care that they require.

Proposal : Principle 10 - It will be important for the Royal Commission to consider the importance of alignment between systems and funding bodies in addition to interfaces between them. Better alignment of funding rules across services with consistent incentives will improve access and a more consistent quality of care. A system which incentivises collaboration will improve integration of services.

Finally, Principle 12 states that the new program should 'be capable of being implemented, monitored and evaluated'. This increased emphasis on overall governance and accountability is essential to the

overall aged care system as well as to specific programs such as medication management.

The underlying question which will require significant investment of resource will be 'What does

success look like?' . 'Success' having multiple definitions across health, quality of life and financial

lenses. Essential to determining the definition of success will be to involve a broad range of

stakeholders - particularly older Australians.

Ward MM would also suggest rigorous dedication to the process of short and well measured program

pilots. In areas such as medication management, key partners, such as Ward MM, can support such

initiatives to create a nimble, responsive and consumer directed aged care service.

Proposal: Principle 12 - Engage consumers as well as broader aged care stakeholders at the very outset to ensure the program delivers on community expectations. Support a regular and disciplined quick piloting model for program enhancements to mitigate risk and deliver on a continuously improving system.

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Question 2: How could we ensure that any redesign of the

aged care system makes it simpler for older people to find

and receive the care and supports that they need?

Medication Specific With respect to improving access to medication management services, key changes to consider should

include:

Medication review access available across all support streams. This will ensure

medication reviews are accessed proactively to prevent unnecessary future harm (Page 4 WMM Submission describes medication-related harm in Australia).

Australia currently spends $1.4bn on hospitalisations resulting from medication

related harm. Proactive medication review, when an individual is at risk of harm, as

opposed to already experiencing harm, could significantly impact this cost. Taking a proactive preventative approach, even in the Entry Level aged care stream, could

positively impact the number of individuals progressing to the more advanced care

streams.

Empowering fil! stakeholders involved in the delivery of medication related care,

including the consumer and their family, to request a review of the individual's

medications.

![ the above is not possible and access to medication review services must continue

to be restricted to only be referrable via a GP, then a new process to reduce

administrative burden should be introduced. This may include allowing for Standing

Referrals (a permanent order from the GP for referral to the service if the consumer meets certain criteria).

Ensuring all consumers currently at risk of medication-related harm receive a

medication management plan. A suitable evidenced based risk form could be

developed for GPs and care providers to assess who is at risk and recommend the

service (Page 10 WMM Submission describes a suitable evidence-based risk rating

tool).

Review criteria should be based on current overall risk of medication-related

harm rather than a list of reasons such as 'recent hospitalisation.'

Enhancement of services such as those offered by NPS MedicineWise, Dementia

Australia, PHNs, Pharmacy Peak Bodies eg (PSA, SHPA) and others with specific focus

on improved visibility and access to consumer medication information for the

elderly.

Broadening the channels of communicating medication and health education

programs such as through social clubs and GP clinics. This could be promoted

through Primary Health Networks. As the experts in medication, medication specific information should be pharmacist-led.

Enhanced Quality Use of Medicines programs in residential and supported aged care

which include sufficient resourcing to support education for residents I families in . Solution 2 Page 13 WMM Submission advocates for 'more t ime on

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ground' for clinical pharmacists to undertake an enhanced role in education

activities.

With respect to improved consumer choice and controls over the services they receive, key changes

to consider include:

Solution 5 Page 18 WMM Submission proposes harnessing data to inform accountability and quality of care. This accountability should translate to insights accessible by the consumer when making choices about their care.

Consumers need to be fully informed of the types of medication management services

available to them to make informed choices of which service is best for them.

Informed choice can be enhanced by transparent reporting of the quality of

medication management service providers.

General Comments The following recommendations relate to accessing all aged care services:

• An alternate approach to online services such as My Aged Care could enable Care

Finders, individuals, families, GPs, social services etc to search for services based on

desired outcomes and needs. The system would enable consumers to create their own 'package' by selecting providers which meet their individual needs and desired

outcomes. As a very simple example:

Citizen Jane would like to :

• Become more active

• Reduce her risk of falls

• Tackle her loneliness

• Get help with daily bathing

Provider A Provider B

Become more Walking Group active

I Reduce her risk Medication Review of falls Falls risk review

Chair lift instalment

Tackle her loneliness

Get help with daily bathing

Walking Group Transport services Retirement village accommodation

I Medication Review Hand rail instalment

Social clubs including chess and book clubs

In-home care support

The system should allow Citizen Jane to select the services she needs from each

provider to make up her individual package.

o The Commission may wish to consider the role the private sector could

play in the development of such a tool. Harnessing the skills of the

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technology sector, combined with the competition which could result from

an 'open market' of aged care comparison software products could ultimately improvement the consumer experience and technical

capabilities of such a system.

o Government could support a private sector development of a new 'aged care comparison website' market through the centralisation of aged care

service data - to be accessed directly by comparison websites.

o Consideration of a privatised model of comparison websites should be

included when determining broader aged care funding mechanisms to

ensure that the providers of these websites remain financially viable.

• The proposal to implement a Care Finder model which supports the opportunity for

consumers to engage at a 'face to face' level could certainly enhance access to the

system for older people. The potential implications for a vast, skilled and

geographically available workforce will however need to be carefully considered. To

overcome some of the challenges that the consumer demand for the model may

generate, it would seem sensible to focus Government resources on the governance

and evaluation of such a system rather than the provision. Allowing the free market,

including existing care providers, to provide Care Finder services would improve

accessibility.

o To prevent 'gaming' of the system, Government should provide

independent monitoring of the Care Finder service outcomes. Evaluation should include consumer outcomes and satisfaction with service.

o There may be scope to include a rating system such as the NPS (Net

Promoter Score) from consumers. o Aged care has an opportunity to learn from the NDIS model with respect

to the successful and unsuccessful elements of the model. The Royal

Commission may seek to consult with leaders and consumers in the disability sector to gain their insights into what works best.

Question 3: Information, assessment and system navigation.

What is the best model for delivery of the services at the entry

point to the aged care system?

General Comments Considerations for improving system navigation could include:

• Ability for Care Finder to engage with recipient via telehealth or phone for rural and remote

individuals as required.

• Availability of navigation tools to case managers and other care providers who offer a

'coordinating' role (eg. GP and pharmacists).

• Appropriately skilled Care Finders and Case Managers. A system navigator (Care Finder) and a case manager have different roles. A system navigator needs to be fully informed with

respect to what services are available to each client. A case manager should have a more

bespoke skill set in coordinating and adjusting the services once accessed, depending on the

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needs of the person. Both roles could be undertaken by the same individual if they have the

relevant skil l sets.

• Development of a system which matches Care Finder with recipient based on availability and

location (proximity to home). The system should ideally be accessible by MyAgedCare team

as well as directly by older person I family I GP.

• Flexibility in the model to allow the organisation delivering the Care Finder services to also be

permitted to deliver actual care services. This will support easier access to services for

consumers, particularly when located in more rural or remote locations. Independence of these two services is not necessary when services are monitored and measured

appropriately.

• Engagement of consumers in the development of new tools and evaluate the real-world

utility.

• A dashboard individualised for each consumer which outlines their care package, services received, relevant care plans and service provider contact details.

Medication Specific

Considerations for improving system navigation should include:

• As mentioned earlier, education on the types of, and how to access, medication services available should be enhanced both in the community and residential care. Early introduction

into the topic of medication related harm will reduce the potential for individuals to become

overwhelmed or confused as to their medications upon commencement of a medication planning process. Where possible, these education sessions should be conducted face to face.

• The review of an individual's medications should always be triggered by them facing a risk of

medication related harm. The implementation of a comprehensive Cycle of Medication Management which is led by an accredited clinical pharmacist but referred by range of

potential stakeholders would enable consumers to access a medication review through a range of interfaces providing flexibility depending on the individual's

circumstance. (Solution 1 WMM Submission page 9)

• All medication planning should involve an initial in-depth medication review conducted by an

accredited clinical pharmacist. This in-depth review should, wherever possible, include a

'face to face' discussion with the individual and, where relevant, their family/carers. To enhance access Telehealth should be considered for remote/ rural locations.

Question 4: Entry level support stream. As people age and

need support with everyday living activities, how should

Government support people to meet these domestic and

social needs?

There needs to be more leverage of specialised health professionals, such as clinical pharmacists, to

improve service delivery.

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Medication Specific

Each year 400,000 people present to emergency departments and 250,000 people are admitted to

hospital due to medication-related harm (2). This comes at a cost to the healthcare system of more

than $1.4 billion (2). In addition, there is significant impact on mortality, morbidity and quality of

life for those experiencing medication-related harm (3). Medication-related harm has been associated

with both functional and cognitive decline in the older population (3). Therefore, impacting on the

ageing experience.

Early intervention with respect to medication management will prevent medication harm and

improve medication efficacy and ultimately promote wellbeing at home hence prolonging their time

in the Entry Stream. In addition, early intervention can reduce the burden on the healthcare

system and may ultimately delay transition to higher streams of care (Figure 1).

Figure 1: Proactive medication review and regular review prevents avoidable hospitalisation.

Case study

•:• 70 year old fe male livmg independently at home Entry level Stream

•:• Hypertension, osteoporosis, depression and poor vision •:• Poorly controlled BP (too low), confused and falls at home & fractures her hip •:• Adm1ss1on to hospital - $$$ •:• Hospital acquired pneumonia- $$$ •:• Stroke - $$$ t •:• High care needs and decline 1n quality of life • $$$ •:• Admitted to residential care - $$$

l Care and Hc;ilth

Stream - .

All preventable with proactive medication management with regular review

Medication Management services should be available to all older Australians regardless of their

position in the aged care stream. As demonstrated in Figure 1 of the Royal Commission Consultation

Paper, the Nursing and Allied Health stream traverses all three categories of care proposed in the new

model. Our ideal model for proactive medication management Solution 1, page 9 of the WMM

Submission delivers a holistic, ongoing and complete cycle of care.

Solution 1: The implementation of targeted full cycles of care through an enhanced Residential

Medication Management Review (RMMR) and Home Medicines Review (HMR)

program. Appropriately qualified clinical pharmacists have the skill set to meaningfully impact on the

quality of life and health outcomes for older Australians living at home, utilising respite care and/or

living in aged care homes.

Ward MM recommends proactive annual in-depth medication plans be created for all Australians in

residential aged care and those living in the community who are at risk of medication related harm.

In addition, Ward MM recommends the addition of accredited clinical pharmacist led medication plan

updates.

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The frequency of these updates should be targeted to the needs of the individual based on their

potential risk of medication related harm. Ward MM modelling anticipates that medication plan

updates would occur between 2-3 times per annum. Frequency of updates would be determined by

the initial medication plan {manage medication-related harm) and changes in care needs and

personal goals over t ime.

BEST PRACTICE

Fully supported cycle of care Evidence supporting such a model is

outlined on page 9 of the WMM

Submission.

The most successful models of

medication management include

clinical pharmacists in an ongoing

collaborative role.

Solution 1 describes the increase in funding which is required to promote optimal medication

management at home and in residential care. Addit ional funding is required for follow-up medication

reviews and collaborative case conferencing with the health care team. The government has

announced an additional $25.5 million in funding to improve access to regular reviews with follow-up

however it is presently unclear how this funding will be distributed. Ward MM suggests that in addition

to utilising these funds to support follow up medication plan updates, that accredited clinical

pharmacists be remunerated for the participation in multi-disciplinary case conferences with GPs.

These are currently remunerated for GPs through the Medical Benefits Scheme (MBS) collaborative

care item numbers such as the Comprehensive Medical Assessment.

Ward MM also proposes the removal of caps on the number of reviews permissible for older

Australians.

There is currently a process, albeit limited, for aged care residents and carers to access Clinical

pharmacist education activities. However, there is no comparable process for older Australians living

at home in need of medication education. Cl inical Pharmacist education resources should be available

to entry level Australians through a central source.

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Question 5: Investment stream. What incentives, including

additional funding, could be introduced to encourage

providers to offer greater and more flexible options?

Medication Specific

An opportunity exists for medication management services to be involved in restorative and respite

care. A proactive and collaborative medication management model Solution 1 in WMM Submission

can assist with coordinating medication management needs post a health crisis (hospitalisation etc).

Medication management in respite care is an opportunity to ensure the burden of medication

regimens is minimal on both carer and recipient whilst still meeting the needs of the client.

Timely medication review post hospital discharge has been shown to delay time to

rehospital isation for high risk groups such as clients with heart failure and clients taking anticoagulants

(high-risk medications) (4, 5).

As described above with Entry Level care, Solution 1 in WMM Submission describes the increase in

funding which is required to promote optimal medication management in restorative and respite care.

Telehealth needs to be included in the remuneration model for consumers in rural and remote areas.

Figure 2: Role of medication review in supporting older Australians throughout restorative services

and successfully returning home.

Case study

•:• 70 year old female living independently at home •:• Hype11ension, osteoporosis, depression and poor vision •:• Medications currently well managed through proactive services •:• Admission to hospital for elective knee replacement - $$ •:• Returns home - rehabilitation services $$ •:• Medication reconciliation post hospital isation with a plan for : tapering pain medications and review of depression treatment •:• Clinical pharmacist educates family and patient regarding new medications and ongoing medication plan .;. Recovers uneventfully with improved mobili ty © •:• Stops pain medications and weans off antidepressant medication.

Entry level Stream

l Restorative Stream

Incent ives to providers to offer greater and more flexible options include:

• Appropriate and easily accessible remuneration for services provided.

• A system which supports timely referrals for medication reviews.

• A system which incentivises collaboration between health providers.

Proact ive

medicat ion management and regular

review

1 M edic<it ion

management and regular

rev iew

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• A system which supports communication between care providers and ease of access to

relevant clinical information for clients. • Support excellent quality of care - independent assessment of quality of life, consumer &

family satisfaction etc.

Question 6: Care stream. As people's needs increase and go

beyond what can be managed with entry-level support or

with their carer, they may need care services. What are the

advantages and disadvantages of developing a care stream,

independent of setting?

Medication Specific

Solution 1 {page 9 of WMM submission) discusses the role risk assessment can have in ensuring all

older Australians can access medication management services independent of care stream. The

proposal is to have one medication management system which can be accessed by all older Australians

independent of care stream. This would build in efficiencies and reduce duplication of resources in each stream. It would also reduce the complexity of what is already a complex system.

With respect to medication management and more generally clinical care, the concept of 'reasonable

and necessary' , as used in NDIS, is unclear. Using this definition, all older Australians should receive medication management services however, it does not discriminate with respect to intensity of

services needed. Risk of medication harm and ineffective medications can be rated according to

validated tools (as discussed above). Risk rating will assist with directing the more intensive services

to the higher risk group. This will also invest in patient-centric services tailored to the client's clinical

needs.

Question 7: How could the aged care and health systems work

together to deliver care which better meets the complex

health needs of older people, including dementia care as well

as palliative and end of life care? What are the best models

for these forms of care?

Medication Specific

Greater uptake requires improved access and education of health care staff and the community in

relation to what services are available for people with complex health needs.

Solution 2 (page 8 of WMM submission) partly addresses this as enhanced QUM activities will address the current shortfall in education resources for residential aged care staff. There needs to be a central

source of medication-related information and education services for carers in the community.

Education will include raising awareness of the services available to optimise management of complex

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health care needs. Organisations such as NPS Medicinewise could deliver this service with respect to

enhancing medication education.

The system needs to support research into the current gaps in knowledge to allow for targeted

education and training. Investment in funding translation of research findings into real world impact

is also required.

The Royal Commission Interim Report highlighted the additional need for education of staff and

consumers with respect to medication safety. An undisclosed proportion of the recently announced

$25.S million boost in government funding for medication management services w ill be assigned to

QUM activities.

Solution 1 of the WMM Submission also addresses how a collaborative medication review cycle can

be adapted for older Australians with complex health needs. As people age in residential care, their

medication-related goals often change as their health naturally declines. Regular medication review

with amendment of goals, in collaboration with prescribers and family/resident, will ensure a patient­

centric approach to health service delivery and optimise quality of life.

Figure 3: Collaborative medication cycle of care for aged care residents throughout their health

journey.

Personal care stream

Admission to residentia l care

Case study

- -• 3 months after admission • Natural decline in health • Decision to move to palliation • Medication pla n a me nded - consul t with pain specialist and GP

Pall1at1on

One month after new plan implemented Check pain regimen is effective a nd safe

Continue cycle of care as needed

(\ v

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Question 8: Designing for diversity. How should the design of

the future aged care system take into account the needs of

diverse groups and in regional and remote locations?

Medication Specific

Medication Management services should be available to all older Australians regardless of their

diversity or geographical location. As demonstrated in Figure 1 of the Royal Commission Consultation

Paper, the Nursing and Allied Health stream traverses all three categories of care proposed in the new

model. Our ideal model for proactive medication management {Solution 1, page 9 WMM Submission), delivers a holistic, ongoing and complete cycle of care for all older Australians.

Providing medication management services in rural and remote areas can be challenging. Options

include Telehealth and extended roles for allied health practitioners where there is a shortage of GPs.

Flexibility in the funding system to allow for reimbursement for extended roles in rural and remote

areas will incentivise a collaborative approach.

Question 9: Financing aged care. What are the strengths and

weaknesses of the current financial arrangements and any

alternative options to better prepare Australia and older

Australians for the increasing cost of aged care?

General Comment

Overall, aged care funding and incentive schemes should focus on services which are proactive and

preventative. Proactive medication review services have demonstrated real word benefits by delaying

time to readmission {see Question 4). These types of services can help older Australians to avoid early

admittance to the most resource intensive streams {see Figure 1, Question 4). Government should

consider all incentives which will keep people at home for longer.

Funding needs to have a forecasting element which addresses the expected health and economic

benefits to the individual and the wider community. This should be informed by a clear understanding

of what is driving costs and investigate incentives that would achieve overall savings within the system

without compromising the quality of care.

Financial Principles

The strength of the current system is that it lies at the intersection of the nationally funded health and

social systems as it provides subsidised health care and accommodation. Government underwrites a

significant proportion of the cost of a consumer's needs either through funding to the aged care

provider or through our universal health care system {Medicare).

Government funding should be based on clinical need and risk of the older population and wherever

possible that it is integrated across a person's journey through the proposed streams, rather than the

current siloed funding model. The current model has resulted in inefficiencies in government funding

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along with a lack of funding to support collaborative, patient centred, proactive preventative care. This

presents an opportunity to fund enhanced medication management services across all care streams.

Key to the provision of services such as medication management are that market forces continue to

prevail as outlined in Section 3 (page 14 WMM Submission) of our recent submission to the Royal

commission into Aged Care Quality and Safety.

Government is to be congratulated on the recent boost to funding for follow-up medication reviews

and enhanced QUM activities. However, this is a short-term measure and funding needs to be secured

for ongoing support of these activities. Independent evaluation and reporting of the new funding outcomes are imperative to ensure future funding is allocated appropriately with a vision for long­

term savings and improvement in the quality of life for older Australians.

Question 10: Quality regulation. How would the community be

assured that the services provided under this model are

delivered to a high standard of quality and safety.

Medication Specific

Strategies to ensure that enhanced models of medication management are delivered to a high

standard of quality and safety have been outlined in Solution 4 and Solution 5 of WMM Submission.

There should be full transparency and reporting of compliance regarding the quality standards for the

provision of services such as medication management which includes appropriately qualified specialists engaged to undertake the services in a collaborative team with the relevant clinical and

healthcare professionals such as an accredited clinical pharmacist.

Solution 4 outlines the ongoing need for regulation and peer review of accredited clinical pharmacists

involved in medication management services. This will ensure a good quality of service is provided to

the sector.

Solution 5 discusses the evidence base model for developing and evaluating quality of health care

including medication management services. Alignment of health indicators with the National Health

Performance Framework (effectiveness, safety, responsiveness, continuity of care, accessibility,

efficiency & sustainability) will ensure consistency of health indicators across all Australian health

provider sectors.

In terms of the proposed changes consideration should be given to a phased implementation plan

(seeded funding) and or pilot programmes to capture the learnings and modifications prior to

national and full roll out. Involving consumers in the pilot phases is imperative to ensure the new

models meet community expectations.

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References 1. Australian Institute of Health and Welfare. The National Health Performance Framework: Australian Government (METeOR, Metadata Online Registry). 2009 [Available from: https://meteor.aihw.gov.au/content/index.phtml/itemid/435314. 2. Pharmaceutical Society of Australia 2019. Medicine Safety: Take Care. Canberra: PSA. 3. Elliot RA, Booth JC. Problems with medicine use in older Australians : a review of recent literature. Journal of Pharmacy Practice and Research. 2014;44:258-71. 4. Roughead EE, Barratt JD, Ramsay E, Pratt N, Ryan P, Peck R, et al. The effectiveness of collaborative medicine reviews in delaying time to next hospitalisation for patients with heart failure in the practice setting. Circulation:Heart Failure. 2009;2{5):424-8. 5. Roughead EE, Barratt JD, Ramsay E, Pratt N, Ryan P, Peck R, et al. Collaborative home medicines review delays time to next hospital isation for warfarin associated bleeding in Australian war veterans. Journal of Clinical Pharmacy and Therapeutics. 2011;36(1) :27-32.

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