Aged Care Act 2024 · Support at Home
A leadership resource on the monthly care management contact requirement: who is covered, what counts, the reporting deadlines, regulatory exposure, the rules on automated and AI assisted calling, and what families are entitled to know.
Every active Support at Home participant receiving ongoing services should receive at least one direct care management activity each month.
At 4% monthly coverage, a provider is reaching only 4 of every 100 covered participants each month.
Moving from 4% to 100% is a 25 fold increase in documented monthly contact volume.
The Aged Care Act 2024 commenced on 1 November 2025, alongside Support at Home. Support at Home guidance states that registered providers must deliver care management activities to all participants, and in practice must deliver at least one direct care management activity every month to each participant.
The operational issue is not merely more calls. The requirement is a care management function: monitoring needs and risks, supporting the participant and registered supporter where relevant, documenting the activity, identifying escalation needs, and maintaining a defensible record.
Automated calling and AI assisted tools may help close the capacity gap, but the safest regulatory position is that technology should assist care management rather than replace accountable human oversight. Fully automated calls should not be treated as the sole proof of monthly care management unless the regulator or legal counsel gives specific confirmation.
The most important question is the denominator: who exactly counts toward the monthly contact population. The requirement should not be applied to every person in a health system unless those people are active aged care participants under the relevant program. The correct working denominator is likely active Support at Home participants receiving ongoing services, participants on pathways where care management is mandatory, and self managed participants, because mandatory care management still applies.
Do not assume the denominator is all patients, all older adults, all residents, or all people known to the organisation. That would overstate the compliance population and muddy the strategy.
| Population type | Counts toward the 100% monthly target? | Notes |
|---|---|---|
| Active Support at Home participant receiving ongoing services | Yes | Primary covered population for monthly care management contact. |
| Self managed Support at Home participant | Yes | Mandatory care management still applies. |
| General hospital patient not enrolled in Support at Home | Confirm | Do not include unless another aged care obligation applies. |
| Family member, carer, or registered supporter | Sometimes | The monthly activity may be with the participant or registered supporter, but the participant remains central. |
| Residential aged care resident | Different pathway | Residential care has separate care and reporting obligations. Do not blend with Support at Home without confirmation. |
Support at Home guidance states that care management helps ensure care reflects preferences, cultural practices, and changing needs. Care management activities include care planning, service planning and management, monitoring, reviewing and evaluating, and support and education.
| Status | Requirement or risk area | Timing | What must be achieved |
|---|---|---|---|
| Red | Monthly direct care management contact | Active now | Every active participant needs at least one documented direct care management activity each month. |
| Red | Documentation | Every month | Record completed contacts, failed attempts, refusals, registered supporter contacts, escalation decisions, and follow up actions. |
| Red | Incident escalation | Immediate / 24 hours / 30 days | Priority 1 reportable incidents within 24 hours, Priority 2 within 30 days. Police reporting may also be needed for criminal matters. |
| Red | AI and automated calling | Before deployment | Do not rely on fully automated calls as sole evidence of care management without human review, consent and privacy controls, and escalation pathways. |
| Amber | Current monthly cycle | By month end | Close the month with every participant marked as completed, attempted, refused, unreachable, supporter contacted, or escalated. |
| Amber | Quarterly financial report | Quarterly | Prepare required financial and labour cost reporting. Q4 2025 to 26 is due 4 August 2026. |
| Amber | Annual reporting | 31 October each year | Submit the Aged Care Financial Report and Provider Operations Collection Form. |
| Green | Compliance ready operations | Ongoing | Maintain a live monthly dashboard, workforce capacity model, privacy controls, escalation log, and quality audit trail. |
There does not appear to be a separate Commonwealth monthly outcomes report solely for the monthly care management calls. However, registered providers must keep records and submit regular financial and operations reporting. The Quarterly Financial Report is a general aged care financial obligation that continues across programs, so the early quarters of 2025 to 26 predate the Support at Home commencement on 1 November 2025.
| Quarter | Reporting period | Due date | Notes |
|---|---|---|---|
| Q1 2025 to 26 | 1 Jul to 30 Sep 2025 | 4 Nov 2025 | Past due. |
| Q2 2025 to 26 | 1 Oct to 31 Dec 2025 | 14 Feb 2026 | Past due. |
| Q3 2025 to 26 | 1 Jan to 31 Mar 2026 | 5 May 2026 | Past due. |
| Q4 2025 to 26 | 1 Apr to 30 Jun 2026 | 4 Aug 2026 | Next major quarterly date from this review. |
Q1 date confirmed against the Department schedule. Confirm Q2 to Q4 exact dates against the official Aged care financial reports calendar 2025 to 26 before relying on the table.
| Report | Due date | Key content |
|---|---|---|
| Aged Care Financial Report | 31 Oct each year | Annual financial and prudential reporting. Support at Home providers report income and expenses at the program level, plus related provider level financial statements where required. |
| Provider Operations Collection Form | 31 Oct each year | Annual operations information: executive details, governing body membership, compliance statement, diversity information, common complaints and feedback, and key quality improvements. |
Monthly contact can surface risk, which makes escalation design essential. A call model that discovers abuse, neglect, suicidal intent, medical deterioration, or unexplained absence but does not escalate appropriately can create serious regulatory exposure.
| Incident class | Reporting timeframe | Practical meaning for monthly calls |
|---|---|---|
| Priority 1 reportable incident | Notify the Commission within 24 hours of becoming aware. Outstanding detail within the following 5 days. | Any call indicating serious injury or discomfort requiring treatment, unlawful sexual contact, unexpected death, unexplained absence, or a police reportable concern must move immediately to the incident pathway. |
| Priority 2 reportable incident | Notify the Commission within 30 days of becoming aware. Final report within 60 days of notification. | Lower priority reportable incidents still need recognition, documentation, review, and reporting within the deadline. |
| Criminal or ongoing danger | Police notification may be required. If unsure, report to police. | AI, volunteers, and routine call teams should not hold these issues. They should trigger immediate escalation to trained staff and emergency or safeguarding pathways. |
Assumption: current baseline is 4% of the covered population receiving one monthly contact. Minimum time assumes 15 minutes per direct care management activity and does not include documentation, failed attempts, quality review, supervision, follow up, escalation, travel, or reporting preparation.
| Covered population | Current 4% contacts | Required contacts | Monthly gap | Min hours / month | Current hours | Hours gap |
|---|---|---|---|---|---|---|
| 25,000 | 1,000 | 25,000 | 24,000 | 6,250 | 250 | 6,000 |
| 13,000 | 520 | 13,000 | 12,480 | 3,250 | 130 | 3,120 |
| 6,000 | 240 | 6,000 | 5,760 | 1,500 | 60 | 1,440 |
There does not appear to be a simple fine per missed monthly call. The more likely legal exposure is through breach of provider obligations, failure to comply with conditions of registration, reportable incident failures, false or misleading information, poor documentation, or serious provider duty failures where safety, health, or wellbeing is placed at risk.
For offences or contraventions where the Commonwealth penalty unit is $330, indicative maximum dollar exposure is calculated as follows.
| Issue | Penalty units | Approx. max at $330 | Risk relevance |
|---|---|---|---|
| Failure to comply with reporting requirements | 250 | $82,500 | Relevant if required reporting is missed or deficient. |
| Significant or systematic registration related breaches | 500 | $165,000 | Relevant where the problem looks systemic rather than isolated. |
| False or misleading information or documents | 100 | $33,000 | Relevant if reporting or records overstate compliance. |
| Serious provider duty failure, organisation | 1,000 | $330,000 | Relevant if conduct creates serious risk to a person receiving care. |
| Serious provider duty failure causing death or serious injury, organisation | 4,800 | $1,584,000 | Highest exposure category identified for non individual providers. |
There is no obvious blanket prohibition on automated calling or AI assisted tools for Support at Home contact workflows. However, privacy, consent, data security, telecommunications, record keeping, and care management accountability all remain in force.
| Technology use | Status | Regulatory interpretation |
|---|---|---|
| Automated reminders to schedule monthly check ins | Lower risk | Useful operational support if consent, contact preferences, and opt out are respected. |
| AI assisted scheduling and routing to care partners | Lower risk | Appropriate use of technology to close contact gaps. |
| AI structured screening with human review | Medium risk | Useful if red flags, distress, unmet needs, and non responses are reviewed by trained staff. |
| AI generated care note or summary | Medium risk | Treat as a draft requiring human review before it becomes part of the care record. |
| Fully automated call counted as care management without human review | High risk | Do not rely on this as sole evidence of the monthly requirement without legal or regulator confirmation. |
| AI closes escalation or makes care decisions | Very high risk | Care decisions, safety escalation, and incident classification require accountable human oversight. |
| Person or role | Automatic right to call reports? | Practical guidance |
|---|---|---|
| Participant | Yes, central party | The information is about their care. They remain the central rights holder and decision maker unless legal authority says otherwise. |
| Registered supporter | May receive relevant information | They support the older person to make and communicate decisions. This does not automatically make them the decision maker. |
| Appointed decision maker, guardian, or attorney | Within legal authority | Share only within the scope of their valid appointment and authority. |
| Family member not registered or authorised | No automatic right | Obtain participant consent or confirm another lawful basis before sharing routine call reports. |
| Emergency contact only | No automatic routine access | Emergency contact status is not the same as care information access. |
| Family or supporter in an immediate safety situation | Possible exception | Disclosure may be justified where needed to lessen or prevent a serious threat, subject to privacy and safeguarding rules. |
The safest strategy is a delegated, supervised care management model that uses technology for scale while preserving human accountability.
| Tier | Who handles it | Purpose | Escalation |
|---|---|---|---|
| Green, routine monthly contact | Care partners, trained staff, trained volunteers, or supported call team | Complete the structured monthly check in, document, identify changes or concerns. | Escalate on any risk, distress, unmet need, refusal, or non response pattern. |
| Amber, elevated concern | Care partner, chaplain or pastoral carer, social worker, service coordinator, nurse, or clinical lead | Respond to loneliness, grief, spiritual distress, carer strain, family concern, service breakdown, or changed needs. | Document the response window and assigned owner. |
| Red, immediate safety concern | Emergency services, safeguarding lead, clinical escalation, incident manager | Respond to suicide risk, abuse, neglect, unexplained absence, medical emergency, or criminal concern. | Immediate escalation. Consider reportable incident and police notification deadlines. |
These source notes are included for review and should be checked by legal and compliance counsel before external reliance.