What is the risk of NOT providing Allied Health in Nursing homes (for boards and execs)

10 KEY questions on allied health that all nursing home organisations boards, executive and leadership and clinical risk management staff SHOULD be able to answer  

Introduction before getting to the questions.

How did we come to this allied health situation? Allied health used to be incentivised to be provided under the previous ACFI (Aged care financial instrument) from 2008 to 1st October 2022. There is no separate inbuilt incentivised funding for allied health in the AN-ACC starting October 1st. Government are saying nursing homes should fund allied health still and not cut levels at all (in fact should increase them) because of the AN-ACC model itself, and also increased funding available. Providers however facing financial losses, workforce and COVID, compliance risk and adapting to a new funding system, may be considering ways to cut costs such as allied health they feel may not need to be required from expensive/hard to find allied health professionals and can be provided by other cheaper staff. Although in this environment cutting costs is of course completely understandable, failure to consider short and long term risks of reducing allied health professional levels can lead to long term costs far outweighing short term savings. It may also be very very difficult to replace allied health down the track if/when a nursing hom decide again they are needed or could be funded.

Why is Allied Health in the AN-ACC such a controversial issue, and one for your board/executive team to have a careful considered risk management strategy for?

  • The care of older Australians is of high importance to communities, and one of the leading voting decision making items in the last federal election.
  • Public perception of nursing homes and clinical care are at all time lows after the Royal Commission in particular.
  • The Royal Commission clearly called for more and higher standard of Allied Health than was being provided under the ACFI
  • DOH and policitians on all sides are stating in many forums are stating that allied health as being previously provided under the ACFI not necessarily appropriate for residents clinical needs.
  • DOH and government in essence are alluding to nursing home providers and allied health providers providing poor quality low skilled massages for financial gain only, not the benefit of residents they are paid to look after.
  • Government and media scrutiny (Australian Ageing Agenda, Seniors News, Inside Ageing, Aged care news, Sydney Morning Herald) on the Allied health issue including Senate and QLD government submissions and evidence
  • A Senate petition was lodged with over 20,000 signatures calling for mandatory funding and inclusion of 22 minutes a day of allied health and included support from prominent Australians David Campese, Tracey Spicer and Danny Green who had parents in aged care that benefited from allied health.
  • External advisors offering advice such as this advice from Mirus Australia that may be read by some as going against DOH and government advice (note we are not implying or accusing Mirus of anything inappropriate in offering this advice, and we note that they also refer to the requirements to provide physiotherapy and allied health in the Quality Standards and Aged Care Act).


  • Allied health workforce shortages and competition sourcing allied health
  • Public expectations on physiotherapy and allied health are very high. Communities expect facilities to provide physiotherapy and allied health
  • Residents and familys have gotten used to a large number of residents (up to 80%) regularly receiving 80 minutes per a week each of allied health (11.42 per a resident per a day on average) and this will not be provided in many cases by providers after 1st October 2022
  • Public, media and government awareness of this advice and that nursing homes are widely cutting hours, terminating allied health employees, cancelling contractrs or not renewing allied health services due to financial needs not clinical needs. Specifically what is being widely reported and with ample evidence is that there is a clear strategy from many providers to replace previous ACFI funded allied health professionals registered by DOH to provide pain management (mostly Physiotherapists and Occupational Therapists) with cheaper less qualified staff
  • Its important to consider at Board and Executive level of Nursing homes what personal and collective risk are you undertaking, or should have awareness is being undertaken, in regards to allied health provision at your facility/s.
  • Boards and executives may be liable for negligence and failure of duty of care requirements if they can be shown to have been shown, or should have known, that a clinical risk and safety issue in regards to allied health existed prior to an adverse event with an older adult. This liability extends even after a board member/executive leaves their role.


What is the current mood on Allied Health and expectations of government, politicians and Department of Health and the Quality and Safety Commissioner?

Watch the senate hearing and punlic evidence from August 25th 2022 regarding allied health for a report to parliament due August 31st,  (link below clickable or click here  )


Relevent parts from Department Health. For context in full please consider the full link below of the hearings this section from DOH/Quality and Safety Commissioner starts at 17.20.25 https://vimeo.com/744018570
as well as the public hansard of the evidence here https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Community_Affairs/AgedcareReform/Public_Hearings

10 KEY questions on allied health that all nursing home organisations boards, executive and leadership and clinical risk management staff SHOULD be able to answer  

1/ Do you have a long-term allied health strategy (including recruitment/retention, quality and safety with KPIs) and is the strategy regularly updated to sufficiently protect board members, executive and leadership teams and ensure duty of care for residents?


2/ Have you documented clearly cost and requirements of your allied health strategy for all your stakeholders? Is it simple, easy to understand and a complete summary of information on expectations about allied health in the AN-ACC after October 1st, 2022?  


3/ In terms of Risk Profile how would you rate Allied Health as a potential issue in your Risk Matrix (High, Medium, or Low) in terms of

  1. a) Star ratings
  2. b) Falls 
  3. c) Hospital admissions
  4. b) Increased workload on other staff i.e., RNs or carers replacing previous allied health staff/services
  5. c) Potential Quality and Safety Commission investigation, penalties, sanctions (including time responding and reputational risk)
  6. d) Resident and family complaints (including time responding and reputational risk)
  7. e) Effect on Clinical Risk and Safety if non-AHPRA registered, university qualified Allied Health professionals (see definitions below) are providing alternative allied health interventions?
  8. f) Occupancy rates and decision-making process of residents and families choosing your facility over others with allied health?

Is the risk profile above consistent with your organisations risk appetite at board and executive level?


4/ Is your organisation complying with the allied health requirements and intentions of allied health in the Quality Standards and Aged Care Act? Are these requirements understood and documented for all staff (including carers, diversional therapy, and allied health assistants). Are you confident that there is sufficient documentation and quality assurance measures in place to ensure that allied health provision is appropriately delivered with due diligence and care?


5/ Does your organisation meet Department of Health expectations of at least 8 minutes per a resident per a day of allied health in Aged Care Financial Report now and in the future? Specifically, are you meeting the expectation that DOH have set of at least 8 minutes a resident per a day of university educated, AHPRA registered allied health professional minutes (such as physio/OT not lifestyle or other)?


6/ Do you also record and show stakeholders allied health professional minutes of care per a resident per a day? Do you have a method of transparently recording and publicly reporting allied health professional minutes that can be seen by your stakeholders and external agencies to give confidence what is reported in the Aged Care Financial Reporting Minutes is accurate and what occurs at floor level?


7/ Does your organisation in ACFR also meet Department of Health expectations regarding Allied Health spend of at least 4% of spend? Following on from above, do you also record accurately and in a way that gives stakeholders confidence that goes into ACFR how much spend on allied health professionals, broken up into professions?


8/ What allied health professionals and services do your residents want and expect now and into the future? Do you feel confident your organisation can consistently provide access to each? Outline your risk management plan and strategy of recruitment, retention of allied health staff, and how you will manage expectations on allied health from stakeholders including how you will manage media/government coverage of the issue.


9/ Are you and your staff/residents able to distinguish between different types of allied health professionals and services? Do you feel that your residents (where able cognitively) and staff can make informed and feel safe that their choice of allied health treatment i.e., exercise, massage is provided by someone appropriately qualified acting in scope of practice?


10/ Do you and your clinical governance team executive and board feel confident in your clinical risk framework that includes allied health (credentialling, AHPRA registration and insurance check, police checks, covid and infection control, training, clinical safety, and scope of practice for different allied health interventions)?

Concerned  about your score or any aspect of clinical safety and risk management after completing this review of your allied health strategy? Please contact privatepractice@aachealthgroup.com.au, or call 1300 574 462 and ask to speak to our Operations Manager and Compliance Team who can arrange a confidential, no obligation discussion of your allied health compliance and needs.

Additional Essential Information on Allied Health for Risk Management and Clinical Quality and Safety

your organisation might want to consider (we recommend sending to board/executive team to show that you have considered as part of your allied health risk management plan) – Please feel free to use but keep links below and credit any information below as courtesy of AAC Health Group and include our email privatepractice@aachealthgroup.com.au and website www.aachealthgroup.com.au
MAIN ONE that DOH and Quality and Safety Commissioner and enquiries public/staff/allied health are referred to, and they recommend printing and showing has been provided is the public one on DOH website

Allied health IS expected to be provided by nursing homes by DOH and legislation


What Allied Health is expected to be on Aged Care Financial Reports?

Requires reporting on spend for each Allied health Profession (see definitions we recommend being very clear on definitions and not using the term “allied health” without adding detail of exactly which profession providing related to a position description see below for these)



Reporting Direct Care minutes of Allied Health to meet expectations of Department of Health and Quality and Safety Commission (8 mins resident per a day from an AHPRA registered, university qualified Allied Health Professional such as a Physiotherapist, Occupational Therapist)

We recommend publicly displaying in certificate form from each of your Allied Health Professional Providers individually and collectively as a total signed by your Director of Nursing/Director of Care/Facility Manager close to the main reception near the Quality Standards like this facility does.



What is Allied Health exactly? What are the different professions and how are they regulated and enforced to ensure public safety?

AHPA the peak body for AHPs considers ONLY university educated health professionals as allied health. It does not consider Diversional Therapy/Recreational Therapy/Lifestyle Officer/Activity Officer/Allied Health Assistant as allied health. This means that the peak body for allied health does not consider these professions as being able to provide allied health directly in scope of practice for insurance and clinical risk management and client safety.
(NOTE – Also does not include Nursing so RN/EN cannot be considered for providing allied health either)
What does each Allied Health Professional Do Exactly?  

Definitions for Allied Health Professionals from Department of Health (linked from the Document “What impact will An-acc have on allied health” from their website)



Allied Health registration standards (enforcable at national level by Australian Health Professional Regulatory Authority, not applicable to self regulating non AHPRA professions.
* Requirement for minimum acceptable university qualification and which universities
* Require minimum insurance levels (public and professional indemnity)
* Clinical supervision and reporting requirements
* Professional standards such as privacy, clinical safety, risk management, infection control and more
* Ongoing record of continuous professional development
* Note taking and documentation
* Complaints handling
* Advertising etc
* Any member of public can easily make a complaint about an organisation/allied health professional service on the AHPRA site
What about “allied health” 
Our legal and insurance advice is that anyone not listed by AHPRA and AHPA, and considered by DOH could lead to considerable risk in the event of adverse events for older people if involving a staff member performing “allied health” interventions outside scope of practice and position.
AHA/lifestyle replacing or seen to be replacing university trained AHPs registered under AHPRA pose considerable insurance and clinical safety risk  in the event of adverse events for frail older adults especially in relation to falls, fractures hospitilisations and death if
* not acting in scope of practice for intervention given ie assessment
* insufficient training in role
* insufficient supervision (direct and indirect)
* lack of national registration body to enforce standards
* no requirement ongoing professional development
* no requirement to have own insurance
For example Non-regulated allied health working in RACF such as Lifestyle Officer/Recreation Officer/Diversional Therapist/Activity Officer or Allied Health Assistant – Would not be covered by insurance for a supervising allied health professional either direct or indirect supervision if does not meet minimum standards of the scope of practice for that profession and minimum requirements ie an allied health assistant should have at least a CERT IV in Allied Health assistance or a year full time under an experienced physio or OT who signs off on this training, as well as a signed supervision plan that is regularly monitored upgraded and changed and includes direct and indirect supervision and ongoing professional development. Otherwise the supervising therapist would be liable for any adverse events, from AHPRA and insurance point of view, civil liability for harm to an older resident that could be perceived to be caused by someone performing allied health outside scope of practice and training, and insufficiently supervised. Even an experienced DT/AHA that lacks the qualifications above could be potentially liable in the event of an adverse event.
For example have a look at this position description for a Lifestyle Officer, and an Allied Health assistant. Do you feel confident that your legal, insurance and risk would be managed with allied health interventions previously provided by physios for example? Would be a nurse in scope of practice, and with sufficient time, be able to replace other allied health professionals signing off on these allied health interventions if visiting AHP unable/unwilling to sign off?
Allied Health Assistant Position Description

Can a Diversional Therapist/Lifestyle/Recreation Officer/AHA in Scope of practice offer allied health interventions directly that have previously been supplied by such as massage, tens, exercise

As per above DOH and AHPA definitions these professions are NOT considered Allied health.
Depending on qualifications and scope of practice a DT can provide much needed allied health services to residents. Unfortunately neither AHPA or DOH currently recognise DT as an allied health profession, or to meet expectations of 8 minutes resident/day of allied health professionals.
The DT professional group Recreational and Diversional Therapist Australia CEO spoke with AAC and confirmed they do not believe exercise (group or individual), massage, heat pack, tens, assessing residents for falls or prescribing equipment is in a DTs scope of practice and they are telling their members this also.
Note Diversional and Recreation Therapists are a self regulating profession currently, not a member of AHPA or enforced via AHPA, and does not require a university degree to be in this profession.
Uico Heading Element@2x

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