Accountability doesn’t stop at your front door: what the new ‘associated provider’ rules mean for aged care

From 1 November, aged care providers will need to take a closer look at how third parties fit into their service delivery. Under the Aged Care Act 2024, “associated providers” are now formally recognised as organisations delivering funded care on behalf of a registered provider. The goal is transparency; the consequence is deeper accountability. Providers must be able to prove that their systems for quality, feedback and complaints extend beyond their own workforce.

Transparency meets accountability

The Aged Care Quality and Safety Commission wants a clearer view of who is delivering care, how these arrangements are managed and whether the systems overseeing them are fit for purpose. Providers must now notify the Commission about any associated providers they use, including when those relationships change.

Associated providers can include allied health groups, catering contractors, lifestyle service companies, technology platforms or franchise operators. Whatever their structure, they now fall under the registered provider’s compliance framework. If something goes wrong, the provider cannot deflect blame. Oversight, improvement and response remain their responsibility.

Oversight in practice

This isn’t about more paperwork; it’s about proving control. Providers must demonstrate that they have systems to monitor the quality, safety and consumer experience of services delivered through others.

Complaints management will be one of the key tests. The Commission expects all issues to be handled through a single, consistent process. A unified complaints register should capture concerns about any service, regardless of who provided it. Providers must be able to show that complaints are triaged, investigated and resolved within clear timeframes, that feedback is shared and acted on, and that risks can be escalated and addressed quickly.

Consumer experience will also be a critical measure. Surveys and feedback tools need to capture how associated providers perform as part of the broader care experience. That raises questions for providers: do their systems record which organisation delivered a service when feedback is collected? Are review meetings looking for patterns across different providers? And do those insights flow into continuous improvement, not just internal compliance reports?

Workforce oversight sits in the same category. Every person delivering a funded service is part of the provider’s workforce for regulatory purposes. Screening, training and conduct obligations must extend across all associated providers. Providers will need a clear record of who has been checked, what training has been completed and how compliance is verified.

Data and reporting complete the governance loop. A central register of associated providers, coupled with regular reporting on incidents, complaints and workforce compliance, will create a clear line of accountability. The Commission will expect to see this information used actively in decision-making, not simply stored for audits.

Franchise and network models under pressure

Franchise and network-based models will face particular scrutiny. Where a franchisor receives government funding for services delivered through its franchisees, the franchisor is treated as the accountable entity. Sharing a brand also means sharing responsibility. Franchisees may operate as independent businesses, but under the new Act, the franchisor must ensure that every service delivered under its banner meets the quality, safety and workforce requirements of the Standards.

This will require franchise networks to rethink their governance. Quality systems will need to extend across each franchise site, supported by consistent policies, screening processes and reporting lines. For franchisors that have traditionally focused on brand and marketing rather than care governance, this shift will demand new capability and new discipline.

Extending quality, not just contracts

These requirements are not intended to add red tape but to ensure that governance reflects how aged care is actually delivered: through a network of partners, specialists and subcontractors. The challenge is connecting those relationships into one coherent framework for quality and risk.

For many providers, the task will be to bring associated providers into the existing rhythm of governance – through audits, improvement plans and board reporting – rather than bolting on new systems.

The new framework demands a shift in mindset as much as in process. Transparency may feel uncomfortable, but it also offers an opportunity to strengthen accountability and rebuild trust in how aged care services are delivered.