Australia's aged care sector is undergoing one of the most significant regulatory transformations in its history. In response to the Royal Commission into Aged Care Quality and Safety Final report, the Australian Government has introduced wide-ranging reforms to strengthen accountability, transparency and care quality.

These reforms are necessary. However, they are also reshaping how care is delivered on the frontline. In practice, increased documentation requirements, heightened compliance processes and intensified scrutiny are altering how staff allocate their time and attention, and how they make decisions. Alongside their intended improvements, these changes are creating new tensions between delivering person-centred care and meeting regulatory demands.

Rebalancing aged care reform does not require less regulation, but better aligned regulation. Policies must move beyond specifying what should be done to ensuring that the conditions exist for care to be delivered as intended. Protecting care time, reducing unnecessary administrative burden and incorporating measures of care quality are practical steps that build on existing frameworks rather than replacing them. Together, they offer a way to align accountability with care delivery that reflects the realities of frontline work.

When paperwork competes with care

In residential aged care, frontline staff are increasingly required to navigate a complex set of expectations. A care worker may complete an interaction with a resident and then turn immediately to documentation requirements. At the same time, the resident may still need reassurance, conversation or simply time. Situations like these are not unusual. They reflect the everyday reality of balancing care delivery with regulatory compliance.

Frontline staff interviewed for my research describe how administrative demands displace time with residents. As one nurse explained, there is “so much focus…that we lose track of being out on the floor with residents”, while a manager observed that increased accountability requirements mean registered nurses are increasingly “collecting all this data…rather than providing actual care”. This pattern is built into daily work routines. Staff describe completing as much direct care as possible early in their shift, before documentation demands take over, leaving the remainder of the day dominated by administrative tasks.

These trade-offs play out in the moment, between a worker and a resident. During time-sensitive medication rounds, staff may be required to prioritise procedural tasks while a resident simultaneously requests assistance, creating situations where workers must delay care despite recognising residents’ needs, often having to “say sorry…I can’t help you now.”

The impact is also visible at the resident level. As one resident simply stated, “there is no time to sit and have a conversation.”

A structural imbalance

This is not a question of individual priorities. It reflects how the system is currently structured, where competing demands shape what care is delivered, when and how.

Frontline workers are expected to deliver person-centred care while also meeting detailed documentation and compliance requirements. While both are essential, they do not always align in practice. Documentation is mandatory, visible and subject to auditing. By contrast, relational care, which is central to quality, is less visible and more difficult to measure. As a result, frontline workers must continually prioritise between them, creating a structural imbalance rather than a simple workload issue.

Current regulatory frameworks, including the strengthened Aged Care Quality Standards introduced in November 2025, are designed to monitor what can be standardised and verified through documentation, checklists and procedures. These elements can be consistently assessed across organisations. In contrast, relational aspects of care such as emotional support, responsiveness and meaningful engagement are less easily captured. Yet these elements are fundamental to person-centred care and to residents’ daily experiences.

The government has taken an important step by introducing mandatory care-minute requirements, which specify minimum direct care time per resident. This reform recognises that time is central to care quality and clarifies how much care should be delivered. However, it does not address how that time is protected or prioritised in practice. By comparison, compliance requirements are tightly specified and monitored, with no equivalent mechanism to ensure that care time is not displaced by documentation and administrative demands during a shift. As a result, the system is structured in a way that prioritises compliance work, even when care time is formally allocated.

If the goal of reform is to improve care quality, policy must better align regulatory expectations with the realities of frontline work.

Three policy directions would support this shift.

First, protect how care time is used.

While care minutes establish minimum staffing inputs, they do not regulate how staff allocate their time during a shift. Compliance requirements are clearly specified and monitored, but there is no equivalent mechanism ensuring that care time is safeguarded in practice. The Commonwealth, in partnership with the Aged Care Quality and Safety Commission, could extend existing frameworks by requiring providers, during audits, to demonstrate how care time is protected from administrative demands. This would help ensure that staffing inputs translate into meaningful care delivery.

For example, providers could be required to demonstrate, through staffing schedules and workflow design, how direct care time is prioritised, including limiting documentation during peak care periods such as medication rounds or morning care.

Second, reduce unnecessary documentation

A significant proportion of administrative burden arises from duplicative and low-value reporting requirements that contribute little to care quality or safety. A targeted review led by the Department of Health, Disability and Ageing could identify and eliminate redundant documentation, particularly where reporting does not directly support care outcomes or risk management. Streamlining these processes would reduce unnecessary workload while maintaining accountability.

For example, where staff currently record the same care interaction across progress notes, compliance checklists and reporting systems, those records could be consolidated into a single entry aligned with regulatory requirements, reducing duplication without compromising oversight.

Third, balance compliance with measures of care quality

The existing Aged Care Quality Indicator Program assesses whether procedures are followed and already includes measures of consumer experience. The next step is to use this information more effectively alongside evidence about frontline working conditions. The Aged Care Quality and Safety Commission could consider how existing quality assessments might more explicitly connect resident experience with staff-reported constraints, without creating another layer of routine paperwork. This would provide a more complete picture of care quality, so that regulation reflects what is delivered in practice as well as what is recorded.

For example, quality assessments could include simple resident feedback measures, such as whether residents feel they have sufficient time for interaction with staff, alongside staff-reported indicators of time pressure and delayed or missed care. Such information would complement existing indicators and help identify when formal compliance is not translating into responsive, person-centred care.

The next stage of aged care reform should focus on how regulation works in daily practice. Protecting care time, reducing unnecessary documentation and giving greater weight to residents’ experiences alongside frontline staff perspectives would strengthen, rather than weaken, accountability. These changes would help ensure that care-minute targets and documented compliance translate into meaningful, responsive and person-centred care. Ultimately, effective reform should be judged not only by what providers record, but by what residents experience.

Euphemia Lambert is a PhD candidate in the Department of Marketing at Monash Business School, Monash University. Her research examines how Australian aged care reforms affect frontline staff and care delivery. She has more than 20 years of experience in aged care, including quality and compliance management.

AI Disclosure | AI tools were used to assist with language editing and the transcription of audio data. All analysis, interpretations, and arguments presented in this submission are the author’s own.

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