ADA’s submission to Royal Commission into Aged Care Quality and Safety

13 June 2019

Established in October 2018, the Royal Commission into Aged Care Quality and Safety was set up to investigate the quality of aged care services provided to Australian and consider how best sustainable aged services could be delivered noting future challenges and opportunities.  In particular, the Commission has asked both consumers, their carers and health professionals to contribute to the inquiry.  So far, the work of the Commission has involved many dates of hearings and the lodging of 3580 submissions since January, including the ADA’s own submission. 

To date, the Commission has held 21 days of public hearings in Adelaide and Sydney, featuring a broad selection of witnesses.  The ADA was delighted that one of its nominee witness,  Dr Peter Foltyn, who is a consultant to the Dental Department at St Vincent’s Hospital, Darlinghurst, and regularly attends to patients at a Sydney residential aged care facility every week, was called to provide his expertise on oral and dental care for the elderly and dementia patients. 

Evidence of the neglect of oral health care by aged care providers
The Commission has already heard some particularly distressing evidence about the neglect of oral health care by aged care providers, with one family giving evidence that despite clear instructions from their mother’s dentist to staff at her aged care facility, her upper partial denture was neither cleaned nor removed by staff for weeks–possibly months—on end. 

As a result, the resident developed an inflamed upper palate, was no longer able to swallow her food, and went from having no decay to needing three teeth extracted and a new denture within the space of a few months. Aged care workers from another facility, when asked by the Commission if this kind of thing was common, said “it pretty much happens every day.”  

Issues raised in the ADA submission
Evidence presented to the Commission to date also supports the ADA’s view that the routine neglect of daily oral care provision by aged care services occurs, in part, because management of some services see it as a low priority. When older people enter residential aged care, or start receiving personal care services at home, it is common for there to be either no assessment of their oral health needs, or a cursory assessment at best, with dentists rarely consulted in the process. 

The ADA submission points out that prevention of poor oral health before older people become more functionally dependent and need to access aged care services is critical. Long waiting lists in the public dental system and increasingly unaffordable and low-value private health insurance cover for dental care means that many older people lack timely access to dental care long before they access aged care. The result is that when they first access aged care services, many have unmet dental issues that are overlooked by aged care providers and which worsen over time.  

Home and residential aged care personal care staff receive little to no training in provision of oral hygiene care or oral health screening, particularly to patients with dementia and/or dentate patients, whose natural teeth are more time consuming to clean than dentures. On top of this, aged care service staffing levels are so inadequate that staff are often rushed and thus likely to neglect oral care provision, particularly if residents are resistant to it. 

Other factors reducing access to dental care by aged care recipients include practical barriers such as lack of affordable or suitable transport to dentist clinics for older people with mobility issues, particularly those living some distance from their nearest private practitioner or public dental service. 

The ADA submission also underlines that private dental practitioners face both practical and financial barriers and disincentives to providing domiciliary care, including lack of treatment rooms, equipment and staff support in aged care facilities, travel time and costs, and the complexity of providing safe domiciliary care to patients with multiple comorbidities.  

ADA recommendations to the Royal Commission
There are no simple solutions to these issues. However, the ADA submission has made a range of recommendations which if implemented, would go a long way to ensuring that older people receiving aged care services have access to the oral and dental health care they deserve. 

- Implementation of a Pensioner/Elderly Dental Benefits Schedule along the lines of the current Child Dental Benefits Schedule, as outlined in the ADA’s Australian Dental Health Plan; 

- Inclusion of assessment of oral health and dentition as a mandatory, reportable component of MBS-funded GP health assessments for Australians aged 75 and over, and referral of any patients who have not recently visited a dentist or have potential oral/dental health problems to a dentist for a comprehensive oral examination;

- Examination of entrants to residential aged care or higher-needs home aged care packages by a dentist who can also participate in oral care planning where possible;

- Aged care services to place a referral pathway to a dentist or dental service on record for all new entrants to aged care facilities or higher-needs home care packages;

- Increased aged care staff-to-care recipient ratios and a higher ratio of nursing staff to personal care staff;

- Mandatory Certificate III Aged Care qualifications for Personal/Home Care Workers with education in provision of routine preventive and oral hygiene care for clients with dementia and other complex medical needs as part of the curriculum;

- Strengthening the oral health content of entry-level nursing qualifications;

- Provision of designated areas for dental treatment by residential aged care services, with larger facilities establishing dedicated dental surgeries onsite;

- Federal Government funding support to private dental practitioners to cover any significant travel costs that may be associated with the provision of dental treatment in RACFs or visiting services to under-served rural and remote communities; and

- Expansion of eligibility for the Patient Assisted Travel Scheme (PATS) to cover the costs of public transport to the nearest dental service for patients in rural/remote areas who urgently require basic dental treatment to prevent complications from untreated oral disease.

Further information
Submissions to the Royal Commission are not published on its website, but you can read the ADA’s submission in full at

Before the Royal Commission provides its final report to the Governor-General at the end of April 2020, it plans to make its way to all capital cities and several regional locations around Australia for further public hearings, community meetings, and visits to aged care services. The public hearing program, transcripts of evidence from public hearings, and statements and documents lodged with the Commission by individuals called to appear at witnesses as public hearings can all be accessed at Aged Care Royal Commission

With no closing date set for receipt of submissions to the Royal Commission, there is still time to lodge an individual submission, which can be in your capacity as a dentist with patients in receipt of aged care services, or as the family member of an older person.