Clinical Governance Under Support at Home: What Allied Health Providers Need to Know
Support at Home begins 1 July 2025. Is your Allied Health service ready for Standard 5 compliance?
The Aged Care sector is undergoing the most significant reform in a generation. With the introduction of the Aged Care Act 2024 and the upcoming Support at Home program commencing on 1 July 2025, expectations on providers—especially Allied Health professionals—are evolving rapidly.
A pivotal element of the new Act is Standard 5 – Clinical Care. While much attention has been given to funding models, brokerage structures, and service eligibility, many Allied Health businesses are overlooking a critical point: clinical governance is now central to compliance, even for subcontracted providers.
In this article, we break down what Standard 5 entails, why it matters for Allied Health, and the practical steps you can take to align with the new requirements—without needing a full clinical governance team.
📥 Need practical resources to get started? Download these two free tools to assess your readiness:
What Is Standard 5 – Clinical Care?
Standard 5 of the Aged Care Act 2024 sets expectations for providers delivering clinical care to older Australians. This includes Allied Health professionals such as physiotherapists, occupational therapists, speech pathologists, and others who assess, diagnose, or treat clients.
According to the Aged Care Quality and Safety Commission (ACQSC), key elements of Standard 5 include:
Delivering care that is safe, quality-driven, and culturally appropriate
Monitoring changes in a client’s condition and responding effectively
Documenting care plans, outcomes, and client preferences
Escalating clinical risks or deteriorations
Collaborating with other providers and professionals
This standard applies across all settings—whether care is delivered by a large provider, a sole trader subcontractor, or a mobile Allied Health team operating under a brokerage arrangement.
📄 For detailed guidance, refer to the ACQSC's Standard 5: Clinical Care overview.
Why Clinical Governance Applies to Allied Health
A common misconception is that only "approved providers" or nursing services are responsible for clinical governance. In reality, anyone delivering clinical care is accountable for safe, ethical, and evidence-based practice.
Under Support at Home, many Allied Health services will be brokered or subcontracted—particularly Physiotherapy, Occupational Therapy, and Podiatry. Even if you're not the registered Aged Care provider, you're still responsible for the quality and safety of your services.
And the provider that engages you is responsible for ensuring you meet Standard 5, meaning:
You need clear processes for managing clinical risk
Your documentation must meet care planning and reporting expectations
Your service must align with wellness and reablement goals
You may be included in audit sampling, documentation reviews, or client file checks
If you're not compliant, providers may choose not to engage you—especially as price caps tighten from 2026.
Four Key Clinical Risk Areas in Allied Health (and How to Mitigate Them)
Based on analysis from Aged Care clinical leaders and governance workshops, here are the four most common areas of risk Allied Health businesses face in Aged Care settings:
1. Unidentified Clinical Deterioration
Without structured reassessment, Allied Health clinicians may miss functional, cognitive, or behavioural decline. Deterioration may be dismissed as age-related instead of being escalated.
Tip: Introduce a reassessment checkpoint every 6 sessions or 3 months. Use standardised functional tools and train your team to identify red flags requiring escalation.
2. Inadequate Handover Between Clinicians or Services
Breakdowns in communication between OTs, Physios, SPs, or different organisations can result in duplicated effort or missed risks.
Tip: Develop a concise handover template covering goals, progress, concerns, and referral needs. Require clinicians to send this when discharging or transitioning clients.
3. No Defined Escalation Pathway
If a client’s status declines, who gets notified? Many subcontractors have no formal escalation process, leading to delays in intervention.
Tip: Document a simple escalation pathway, including who to contact at the Aged Care provider. Include it in your SOPs and clinician onboarding packs.
4. Fragmented Clinical Documentation
Documentation may live in email, private notes, or scattered CRMs. Without consistency, clients and providers are exposed to risk.
Tip: Align your documentation process with provider expectations. Send reports regularly, and where possible, access or contribute to a shared system or secure platform.
Where Most Allied Health Providers Fall Short (and How to Fix It)
Here are common governance gaps I see in Allied Health practices preparing for Support at Home:
| Governance Gap | Simple Fix |
|---|---|
| No structured reassessment | Schedule a review at 3-month or 6-session intervals |
| Unclear escalation process | Write a one-page guide and include it in onboarding |
| Reports sent ad hoc or late | Set a standing task to send reports within 5 days |
| Notes focused on symptoms, not function | Use reablement-oriented templates with goal fields |
| No governance clause in contracts | Add one section specifying reporting, audit, and escalation responsibilities |
Addressing even one or two of these gaps significantly strengthens your provider relationships — and improves client outcomes.
Wellness vs Reablement: A Core Compliance Focus
Support at Home and Standard 5 both stress that clinical care must support independence and participation, not just symptom management.
Here’s a summary of wellness vs reablement, as defined in the Support at Home Program Manual:
| Wellness | Reablement | |
|---|---|---|
| Definition | Ongoing focus on maintaining function | Time-limited program to restore function |
| Delivered by | All staff | Allied Health only |
| Example | Encouraging self-care during visits | 6-week falls program post-hospital |
| Compliance | Required across all aged care services | Required under Standard 5.4 |
If your Allied Health service isn’t goal-based, function-focused, or tied to reablement outcomes, you may fall short of provider and audit expectations.
Aligning with Provider Risk and Audit Requirements
From 1 July 2025, Aged Care providers must show that subcontractors and services:
Monitor and respond to clinical risk
Use evidence-based approaches (including reablement)
Maintain consistent, audit-ready documentation
Escalate concerns and changes in client condition
Subcontracted Allied Health businesses that can:
Provide structured reports
Track outcomes
Contribute to collaborative care
…will be preferred partners in the post-reform Aged Care environment.
Practical Steps to Strengthen Clinical Governance
You don’t need a hospital-style governance team. Here are five steps any Allied Health provider can take now:
1. Align Your Templates with Standard 5
Audit your assessments, care plans, and reports. Do they reflect functional goals, reablement outcomes, and clinical risk factors?
If not, it’s time to revise.
📥 Download my Standard 5 Checklist
2. Define Escalation Processes
Map out who your team should contact if they identify a clinical risk. Include this in team onboarding and SOPs.
3. Conduct a Governance Self-Review
Use a basic checklist to assess:
How often clients are reassessed
Whether documentation is consistent
How care is handed over between clinicians
Whether staff understand escalation and deterioration
4. Update Your Brokerage Agreements
Clarify governance in your contracts. Include:
Expected report timeframes
Access to referral info and plans
Escalation and handover expectations
How you align with reablement and audit readiness
5. Train and Upskill Your Team
Standard 5 isn’t just about policy—it’s also about behaviour. Run practical in-services or CPD sessions on:
Clinical note taking
Risk recognition and escalation
Reablement frameworks
Interdisciplinary communication
What Does Clinical Governance Look Like in a Small Allied Health Team?
You don’t need a dedicated clinical governance department to be compliant with Standard 5. Even small Allied Health providers and sole traders can demonstrate strong governance by embedding a few key systems:
Templates – Use structured assessment, reassessment, care plan, and discharge templates that reflect wellness and reablement principles.
Standard Operating Procedures (SOPs) – Create clear, simple SOPs covering escalation, handover, and documentation.
Training – Run informal CPD sessions or provide guidance on Standard 5 topics like documentation, goal setting, and clinical risk.
Audit Habits – Review 1–2 case notes per month to check for gaps in reporting, risk documentation, or reablement language.
Contracts – Make sure subcontracting agreements explicitly include responsibilities for care quality, reporting, and escalation.
Governance doesn't need to be complex — but it does need to be intentional, documented, and consistent.
What Providers Are Looking For in Subcontracted Allied Health Services
As Support at Home rolls out, Aged Care providers are becoming more selective in who they broker services to. Here’s what they’re increasingly expecting from Allied Health teams:
Compliance with Standard 5 – Clear documentation, escalation pathways, reablement goals.
Structured Reporting – Timely, professional reports that link progress to functional outcomes.
Audit-Readiness – Willingness to share documentation and participate in reviews if needed.
All-Inclusive Pricing – Transparency around pricing, with no unexpected charges for admin or travel.
Capacity and Coverage – Ability to accept referrals in priority locations and avoid long delays.
Collaboration – Open communication, shared goal setting, and contribution to care planning if asked.
The providers who subcontract you are still responsible under the Aged Care Act. Help make their job easier — and you’ll get more referrals.
Frequently Asked Questions
Do these rules apply to subcontractors?
Yes. Under Support at Home, subcontracted Allied Health providers are expected to comply with the same clinical care standards as approved providers.
Can I charge travel or admin separately?
No. From July 2025, Support at Home will require all-inclusive pricing. Travel, admin, and documentation must be included in your hourly rate.
Can I deliver group or wellness programs?
Yes — but only if the service is included in the client’s approved care plan and directly supports their reablement or wellness goals.
Group or wellness programs must be:
Purposeful and goal-driven (e.g. improving balance, mobility, or confidence)
Evidence-based and linked to improved functional outcomes
Delivered by appropriate staff (e.g. Allied Health for reablement programs)
Programs that are purely social or passive won’t meet compliance requirements under Support at Home. All services must align with the client’s plan and be billed within the all-inclusive hourly rate.
What happens if I don’t comply with Standard 5?
Providers may exclude non-compliant subcontractors from brokerage arrangements due to clinical and reputational risk.
Final Thoughts
Support at Home is more than a funding shift—it’s a system-wide quality uplift.
For Allied Health businesses, especially those working under brokerage, compliance with Standard 5 is non-negotiable from July 2025 onward.
To remain referrable and relevant, you need to:
Review your documentation and risk protocols
Align with wellness and reablement principles
Upskill your team in practical clinical governance
Show that your service is safe, outcome-focused, and audit-ready
Need support to prepare?
Download both free resources below to get started:
Or book a free 30-minute strategy call with me to discuss how to strengthen your governance and grow your service in the new Aged Care landscape.
