I'm having a read through of the CDNA National Guidelines, touted by Brendan Murphy today at the #agedcarerc as a "comprehensive national plan" for COVID in aged care.

First of all, these are clearly guidelines, not a plan; they say so repeatedly.

#auspol #agedcarerc
Secondly, the entire document itself is only 44 pages long. If you subtract the posters at the end from the WHO on hand washing and coughing and sneezing, it is 39 pages long.

Minus appendices, it is 20 pages long. "Comprehensive"? Hardly. #auspol #agedcarerc
The onus to manage COVID is placed squarely on providers:

"The primary responsibility of managing COVID outbreaks lies with the RCF...All RCF should have access to infection control expertise, whether in-house or not, and outbreak management plans in place." #auspol #agedcarerc
This is the third iteration of this document: v.1 was released 13/3/20, v.2 on 30/4/20, and this version on 14/7/20.

In the first two versions, there was no clarification of the roles and responsibilities of the federal government. We heard this at #agedcarerc today. #auspol
In this revised version, under roles and responsibilities, it states:

- State/territory public health section in the Departments of Health will act in an advisory role
- the regulator "takes a proportionate risk-based approach in responding to situations such as COVID-19"
The Commonwealth's role, according to revised document, is to "work collaboratively with the overall management of the response to support the viability and capacity of the RACF to access services."

Clear as mud? I think so too.

It lists the following govt responsibilities:
So, according to this "national plan," facilities are responsible for managing outbreaks. The regulator does its usual job, i.e., handles complaints and considers accreditation standards (especially as pertaining to infection control). State authorities will provide advice, incl:
And the federal government (Dept of Health) will provide a surge workforce, allocate a state-based manager, provide access to a First Nurse Responder, and give access to GPs and allied health services through the Primary Health Network.

But who's in charge? #auspol #agedcarerc
There's no elaboration on how these agencies interface with one another. No description of coordinated efforts.

There's a handful of bullet points for each agency, most of which reiterate their usual functions. Hardly "comprehensive." #auspol #agedcarerc
The document places a LOT of faith placed in providers to come up with appropriate training for staff and to self-prepare for COVID.

Which is probably why we've seen such uneven outcomes across the sector, uneven training, uneven preparedness #auspol #agedcarerc
As we heard in evidence at the #agedcarerc today, the online training modules that the Dept of Health recommended in these guidelines were voluntary, not compulsory.

Here's the sole mention of the Dept of Health's training modules. Blink & you'd miss it #auspol #agedcarerc
It's astonishing how much leeway is given to providers to determine what is "appropriate," and how little guidance is in the document.

For example, here's what it says about hygiene supplies. "Adequate". What does "adequate" mean? #auspol #agedcarerc
Providers are also instructed to come up with their own individual outbreak management plans.

This "do it yourself" approach seems like an approach that is destined to result in uneven degrees of planning and preparedness. #auspol #agedcarerc
As of today, the document STILL advises providers to only plan for a 20-30% surge workforce. But we have seen time and again that when an outbreak strikes, providers can lose upwards of 70-100% of their workforce, when workers become infected.

#agedcarerc #auspol
This is the extent of the advice given about how to separate infected and uninfected residents.

No advice about which types of facility set-ups could never safely do so (such as facilities with more than one bed per room, shared bathrooms). #auspol #agedcarerc
The other document referred to here, COVID-19 guidelines for IPC in RCF, is also vague and highly open to interpretation.

For example, what does "as far away as possible" mean when describing a reasonable distance between uninfected and infected residents.? #auspol #agedcarerc
Suffice to say, this is hardly a "comprehensive national plan."

It is a set of guidelines - clearly labelled as such - that is now being retrospectively dressed up as a "plan" by a federal government which should have done much more much sooner. #auspol #agedcarerc
And worst of all there is no clear chain of command, which is why we've seen such horrendous confusion and contemptible buck-passing between federal and state agencies and the regulator. Nobody wants to be in charge of this furphy. #auspol #agedcarerc
But even if we give Murphy the most generous benefit of the doubt EVER and call it a plan, it is safe to say it is a failed plan, an inadequate plan, a plan that has resulted in gross suffering and stress for residents, families, aged care workers & providers #auspol #agedcarerc
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