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STANDING COMMITTEE ON FINANCE AND PUBLIC ADMINISTRATION
07/04/2009
Residential and community aged care in Australia

CHAIR —Welcome to representatives of the Queensland Nurses Union. Information on parliamentary privilege and the protection of witnesses and evidence has been provided to you. The committee has copies of your submission. I will now invite one of you to make a short opening statement and at the conclusion of your remarks I will invite members of the committee to put questions to you.

Dr Todhunter —Initially, can I give an apology from our elected officials. They are both unavailable today, so we have other officials appearing. The Queensland Nurses Union thanks the committee for the opportunity to appear at this hearing. I will begin with a brief outline of the QNU’s charter and activities.

The QNU is the principal health union operating in Queensland. It is registered in the state and in the federal jurisdiction as a transitionally registered association. In addition, the QNU operates as a state branch of the federally registered ANF. The QNU covers all categories of workers that make up the nursing workforce in Queensland including registered nurses, enrolled nurses and assistants in nursing employed in the public sector or the private and not-for-profit health sectors. These and other aged care workers are vital in providing the expert care that elderly Australians need. Our members work across a variety of settings from single person operations—

CHAIR —Excuse me. Rather than read your submission, could you give us a summary; otherwise, we will run out of time? We have got the submission and we all read it before you came. If you would like to give us some opening comments, that would be great.

Dr Todhunter —I will take you to a campaign that we are currently running. You may be aware that all branches of the ANF, including the Queensland Nurses Union, have recently launched the Because We Care campaign to promote and create quality care for older Australians. We are seeking four major outcomes. I will take you through those briefly.

CHAIR —I think all of us were at that launch in Canberra.

Dr Todhunter —Can I take you to some points then on each of those?

CHAIR —Definitely.

Dr Todhunter —These are the objectives that the QNU are seeking. Firstly, they are seeking mechanisms that ensure openness and accountability in the way governments spend taxpayers’ funds. Briefly, the QNU are seeking the implementation of mechanisms that require aged-care providers to spend funds received for the provision of care directly on care provision. Funding for care costs should be quarantined as separate funding and should be separately accounted for.

Secondly, we are seeking—and, of course, this is very important to the QNU—fair pay for nurses and care staff in aged care. On average, nurses in aged care receive about $300 a week less than their colleagues working in other areas of the health system. We believe this disparity in wages makes it increasingly difficult to attract sufficient nurses to the sector.

Thirdly, we are seeking the right balance of skills and working hours. The provision of quality care requires adequate staffing levels with an appropriate skill mix. Therefore, the QNU calls for mandated minimum staffing levels in residential aged-care facilities and a suitable nursing skill mix that will address unsustainable workloads and enable delivery of appropriate standards of care.

Changes in enrolled nurse training over the last 10 years have led to enrolled nurses performing more complex nursing activities, including administration of medications. These additional responsibilities, combined with the sharp decline in the number of registered nurses, have increased the workload of all nursing staff in aged care.

Lastly, we are seeking a national licensing system. We believe that licensing of assistance in nursing and carers would have an overwhelmingly positive impact on recruitment and retention of nursing staff by providing a distinct career pathway for these workers. Licensing of direct care staff would also contribute significantly to ensuring that the roles of all levels of nursing staff are clearly defined, thereby contributing to maintenance of optimum standards of care for older Australians.

Senator HUMPHRIES —A different committee had another inquiry into aged care some time ago. The ANF appeared in that inquiry and commented on the extent to which providers were using the Conditional Adjustment Payment to address that gap between what equivalent workers were doing in other parts of the community and what they were doing in the aged-care sector—and nurses, in particular, are the relevant disparity which you refer to here. I remember the ANF asserting that the money was there in the CAP supplement to be able to cover that gap if the providers chose to do so. Of course, that was the ANF, not the Queensland Nurses Union. Do you have a view about that today? It has probably been four or five years since that evidence was given to the committee. Do you think that if what is provided for in CAP by the federal government were dedicated to closing the gap between those two categories of workers there would be enough to do that?

Mr Ross —It is a little while since we have looked at those numbers in the global sense of what we suggest it would take to close the gap between nursing staff in aged care and their counterparts in the public sector and then comparing that with the CAP funding that is available. We are happy to take it on notice, rework those numbers and provide some updated information.

Senator HUMPHRIES —Okay.

Mr Ross —From my recollection of the argument at that time, there were particular problems with directing CAP money towards nurses’ wages. From memory, while there were a couple of hoops that proprietors had to go through in order to access that money, one of those hoops was not a specific acquittal on nurses’ wages. But we can work the numbers and probably provide you with some updated information on that.

Senator HUMPHRIES —I might put the question a more relevant way. The industry is suggesting that the problem is a lack of funding—that the government subsidies simply are not at a level required to address issues like the gap in wage outcomes. One witness today said that the problem was really the business models that providers were using—that they were not spending their money in the most efficient way. Between those two points of view, do you have a view about where the nurses union would fall?

Mr Ross —I think there are a couple of key issues for us. The first of those is to ensure that there is sufficient money directed towards the wages of nursing care staff so that they are paid appropriately. These are submissions that we have made not just before this committee but also in respect of the House of Representatives pay equity inquiry, which is currently underway, and the committee inquiry into the industrial relations legislation. There needs to be, in aged care, money directed to those wages and sufficient money directed towards ensuring that there is an appropriate skills mix and staffing levels within the aged-care facilities. It is our submission that you need both those things in order to attract appropriate numbers of suitably qualified staff to deliver the care, which ultimately is what the program is about—to deliver that quality of care. Let’s get that right first and then have a look to see whether there is enough money to deal with the other areas that the industry needs to address, such as appropriate facilities and those sorts of things.

Unfortunately, the pressure that we have experienced over some years is that, when the employers, proprietors and providers feel that they are not getting sufficient funding, it is our people who get cut—that is, in terms of their hours and pressure to keep wages low and those sorts of things. Let’s get the wages right and the staffing levels right first up and then look at the funding.

Senator HUMPHRIES —Let’s assume that the decision is made that the industry does need more money to address these sorts of issues—the viability of the business models, wage disparities and so on. If the federal government provides that money, should it quarantine it in some way so that the condition of the extra money is that it addresses those wage disparity issues?

Ms Garrahy —Our view is that the money is accountable for and that the providers have some sort of accountability to the government for the receipt of that money, whether that is necessarily quarantining it or just having some accountability mechanisms in place to account for the dollars for care delivery—some evidence of the care delivery. Those sorts of mechanisms are not in place currently.

Senator HUMPHRIES —I think the industry would argue that there is quite a lot of accountability at the moment in the sense that they explain how they spend their money. We have been discussing this morning the information that the industry provide to the department on their cost pressures, the outcomes for patients and all those sorts of things. There is a lot of accountability there at the moment. The industry tend to argue that they just do not have the resources to pay staff at the level that you would see for the same kind of work elsewhere in the industry. To overcome that, you either need to generously increase the allocation so that there is no reason for them not to find extra or you need to quarantine. With respect, I think simply expecting more transparency probably will not solve the problem unless there is a lot of extra money flowing into the system.

Ms Garrahy —If the standards are set, as we have submitted for staffing levels and skill mix and some sort of minimum care hours and so on, then it is clear to see how much money should be spent in those areas. I guess that is more or less a form of quarantining, if you like.

Senator HUMPHRIES —So you are saying that part of the process of setting standards for this sector should be not only mandating outcomes like a certain number of meals per day and a certain number of medication visits and all that sort of stuff but also the amount that the staffing facility are paid.

Mr Ross —There are mechanisms to achieve that. A couple of examples are setting a national market rate for nursing wages of different classifications and, in order to be eligible for funding linked to that market rate, it would be necessary for proprietors to have some form of collective industrial instrument in place that reflected those market rates. That would place a legal obligation on the employers to meet that. It seems to me that that would be a relatively straightforward mechanism, by way of example. With regard to staffing levels and skills mix, we argued at the time the accreditation standards were being developed that there should be specific skills mix ratios included in the accreditation standard that the proprietors would have to show in order to be accredited—that to meet that particular standard they would have to employ certain numbers of certain classifications of staff. Again, that would be reasonably straightforward. Whether you would call that an accountability mechanism or a quarantining, nonetheless there are mechanisms available there to achieve what we are seeking to achieve.

Senator BOYCE —If you use the current classifications, a certain number per low-care occupant and a certain number per high-care occupant and extra for dementia wards and whatever—is that the sort of thing you are talking about?

Mr Ross —Yes, essentially.

Senator BOYCE —You might have one to six, one to three or one to one.

Mr Ross —With the previous funding schemes, going back some time, there were nominal staffing ratios attached to each resident classification. The funding was based around those sorts of structures.

Senator BOYCE —Where I am going with this is that we have had suggestions to the effect that we dropped the distinction between high and low care, because it is no longer meaningful with people coming in from community care, and almost go to a needs based type of thing. Presumably this system could still work but, if we were to change, would a new level of administration be required to make it work?

Mr Ross —My understanding of the submissions on that point is that there is not a submission to do away with the classification systems per se; it is just to do away with the distinction between the group of classifications that are high care and the group of classifications that are low care. Part of the argument, as I understand it, is that, with residents who are classified low care, it is possible to charge them bonds and to have a different sort of structure. I do not think those submissions are at odds with what we are suggesting.

Senator BOYCE —That is what I wanted to check.

Ms Garrahy —A different way of looking at that is to use the comparison between the old RCI category, the hours per resident per day allocation. For example, for RCI category 1, the entitled hours per resident per day was 3.8 hours per day, so providers built that sort of thing into the roster. Perhaps we could look at ACFI to see whether the three modes of ACFI could somehow be worked into a similar model.

Senator BOYCE —The other issue that has come up quite a lot is that there is really no way at the present time for assessing the quality of lifestyle being provided in residential aged care, so it is not just about the level of medical care you are getting but whether it is being delivered with a smile and whether your daughter has to come in and feed you to make sure you get fed and so on. How would the minimal standard system account for that?

Ms Garrahy —I would imagine that the working out of the hours per category per day would need to incorporate those sorts of factors. We know anecdotally—our members tell us—that they just do not have time to do those additional sorts of caring, chatting, supportive sorts of things currently. Whether or not even ACFI would be suitable for incorporating those sorts of calculations I cannot answer.

Mr Ross —I guess the point about some of that work, though, is that that work is not just sitting down and having a chat with the resident. The skilled nurse is having the chat with the resident but also assessing the resident at the same time and different things, so to lose that time—it might be hard to measure the value of that, but that is not to say that the value of that work should be underestimated.

Senator BOYCE —Yes, it can be an early diagnosis method for all manner of things.

Ms Garrahy —Yes.

CHAIR —You can also have a situation where patients will not complain about the pain level that they have because they do not want to be seen to be a burden on the staff because they know how busy they are. In that case it can lead to all sorts of complications.

Ms Garrahy —Yes. That again is another pointer to the fact that licensed nurses and nurses skilled in assessing are really invaluable for the provision of good care.

Senator HUMPHRIES —That is a good point. There has been a debate in front of the committee about whether there is a crisis in aged-care funding in Australia. What is the view of Queensland nurses?

Mr Ross —I think we would probably state that there is a crisis in staffing within aged care. There is material in our submission and also in the submission of the federal body, the Australian Nursing Federation, talking about the reduction in licensed nurse numbers over time. When you compare that against the increase in resident acuity over the same time frame, you see that you are just not getting that expertise to be able to look at the increasingly ill and frail aged. That is a real crisis. Our members complain about workloads; employers that we sit at the table with complain about their difficulties in attracting adequate numbers of staff. There is no doubt that there is a crisis in the staffing in aged care.

Ms Garrahy —The registered nurses who are responsible for providing the supervision of the other staff tell us that they are leaving because they are just so concerned that they cannot meet their professional accountabilities—that there is a place up the road where they can actually meet their professional obligations in addition to getting public sector wages. So that is one of the things that are definitely drawing the registered nurses away from the sector. That is the change in the skill mix that means there are less RNs about.

Senator HUMPHRIES —The evidence before the committee has been that the lack of proper financing in the sector is the direct cause of that staffing or workforce crisis. Do you disagree or agree with that?

Mr Ross —I disagree that the lack of funding is the direct cause of the staffing crisis. I think the question is more complex than that. Our concern really is, as we have been stressing, the accountability issues. Once the funding is directed to where it should be then we can perhaps look at the adequacy of it. Certainly some compelling arguments are being advanced at the moment around the funding difficulties that some of the proprietors are facing, but some of those arguments have been around for a long time. Let us get the staffing levels and the wages of the people who are delivering the care right first, because ultimately that is the best way of delivering the quality of care that is required to those people, and then let us have a look at the funding after that.

We have material, and I am sure there is some of it before the committee, showing that wages have dropped in real terms for registered nurses who are award reliant—and in aged care, as you would be aware, there are large numbers of them. Over the last 10 years, wages have dropped in real terms, so it is not just the gap with the public sector colleagues. If you are working in aged care and you are on the award, you are further behind than you were 10 years ago.

Senator BOYCE —I just want to get a sense of how many of the people you represent would be working under awards and how many would be working to EBAs—or are we talking both?

Mr Ross —We are talking both. In Queensland there are some very big players that have a lot of facilities, and I think you have heard from some of them today. We have agreements with most of those big players. I think there are 470-odd facilities in Queensland, and there are approximately 170 providers, from memory. We would have agreements with, say, 25 or 30 of those larger providers, but they may have 65 to 70 per cent of the facilities in Queensland. So you are looking at about 25 per cent of the facilities and beds being reliant on award rates.

Senator BOYCE —And I am right to think that they are lower than for people on EBAs across the board?

Mr Ross —Yes, but not much lower. For example, we will table these two documents. The first of these is some material that compares the award rates with CPI figures and the Queensland public sector.

Senator BOYCE —So this is where you get your ‘dropping backwards’ statement?

Mr Ross —That is right.

Senator BOYCE —Is this research the union has done?

Mr Ross —This is research the union has done, although I think there has been similar research done in the Productivity Commission report, albeit perhaps on more of a national scale. The first of these documents just shows the award versus public sector versus CPI. The second document has aged-care providers, NACAS and public sector versus CPI from 1990. The first graph in there, as you will see, has a key down at the bottom. It has some Blue Care wage rates versus the NACAS, which is the Nurses’ Aged Care Award—State, rate, and also the Q Health rate.

Senator BOYCE —NACAS is the award for aged care?

Mr Ross —It is the state award. There are notes at the back explaining that, for some of the time, it is the state wage movements of the award and then, after Work Choices, it becomes the AFPC’s rates. If you look at the registered nurse rate under the NACAS, which is the pinkish figure there, and the registered nurse for Q Health rate, which is the orange one, you will see that in 1996 they were essentially the same rate. In 1996 a couple of things happened. We got an enterprise-bargaining regime and we got a different funding regime in aged care. You will see that the award rate over time, against the CPI, decreased in real terms, whereas, as a consequence of the successful bargaining outcomes in the public sector, that rate increased.

You will see the Blue Care rate, which is the purple line, has also increased during that time. But, if you go over to the next page, where instead of Blue Care we show TriCare, the light blue line shows the TriCare registered nurse rate. You will see, notwithstanding that there have been agreements made with that organisation, that the rate has still dropped in real terms. The point I am trying to make is that, while we have agreements with a number of aged-care employers, a lot of the rates in those agreements are still quite close to the award. Some agreements, in fact—

Senator BOYCE —Some mirror the award and others do not.

Mr Ross —That is right. The TriCare agreement works on a mechanism whereby wages are increased by the COPO rate. There has been a fair bit of information put before you in terms of the impact of COPO.

Senator BOYCE —That was quite clever of TriCare, really, wasn’t it.

Mr Ross —COPO is a more global figure, so it covers other things besides wages. But that is the way they have linked their wage increases, and you can see the resulting consequence—

Senator BOYCE —But it throws it back to the government to a certain extent.

Mr Ross —That is right.

Senator HUMPHRIES —Are those weekly dollars on the left-hand axis?

Mr Ross —That is correct. The actual rates are specified behind the graphs, and there are notes on the final page to give some further explanation as to how the calculations are made.

Senator BOYCE —Was this survey done nationally?

Mr Ross —This is material that we prepared within the QNU.

Senator BOYCE —Yes, but have your sister—

Mr Ross —Yes, there is similar work being done nationally.

Senator BOYCE —You mentioned the figure of about $250 a week as being the average difference between public hospital and aged-care sector nurses. Do you mean nurses and nurse assistants, or are we rolling just enrolled and registered nurses into that figure?

Mr Ross —What we can say is that there was a gap, whether for assistants, for enrolled nurses or for registered nurses. The gap for registered nurses is now getting up to around $300.

Senator BOYCE —This information will probably back that up.

Mr Ross —Yes.

Senator BOYCE —I am presuming that there is no significant difference between the national figure and the state figure?

Mr Ross —That is correct.

Senator BOYCE —There is a meaningful gap across Australia?

Mr Ross —That is correct. If you look at the first graph on the first document, which is headed ‘NACAS versus public sector versus CPI’, if you look at the gap between the pink line and the dark blue line, which are the two top lines at the end, you can see that they are getting up to around the $250 to $300 mark.

Senator BOYCE —So I am looking at the bottom black line, no?

Mr Ross —No, if you look at the two top lines on the first graph—

Senator BOYCE —Yes.

Mr Ross —the top one is the RN rate for Queensland Health and the pink one is the award rate. It goes from $700 down to about $520 to $530 or so. That was as at January ‘08, so it is about 12 months in advance.

CHAIR —I said earlier, and I think it has been shown in the evidence, that this industry in some ways has the same challenges that the childcare industry had in terms of getting the community to accept that you have professionals working in it. They are not babysitters; they are actually highly skilled, highly trained and very accountable. In fact, we have had evidence to suggest that aged-care is one of the very few industries that has police checks and reporting mechanisms. The childcare industry also has to meet all those obligations. What are the union’s views and, if you have set about a campaign of attracting nurses back into the field and obviously into your industry, what sort of campaign is it and what has been achieved in terms of trying to retain people? Is it just a matter of salary, or is it other work pressures or the fact that it is perhaps considered by some to be of greater value to work in acute care as opposed to looking after those who have built the nation?

Ms Garrahy —Our national ANF aged-care campaign is focusing on community engagement to a great extent. Liz may like to add something.

Dr Todhunter —We did touch on this in our opening statement. There were four areas that we particularly wanted to address. Certainly, one of the underlying features is the recruitment and retention of staff. We have explained how difficult that it is when there is not wage parody within the profession.

Ms Garrahy —Yes. Big-ticket items are wages and then skill mix and staffing levels. Part of our campaign is to promote those issues.

CHAIR —And an ageing workforce—would that be accurate as well?

Ms Garrahy —Yes. The average age of aged-care nursing staff is greater than the average age of nursing staff generally. Our initial submission to the inquiry identifies some of the research findings that QNU research has demonstrated as issues that would be required to be addressed to recruit and retain nurses. We have commissioned the University of Queensland to do research surveys over a long period—in 2001, in 2004 and in 2007—and the findings of those research surveys of our members each time were that the aged-care nursing staff were less likely to be able to complete their work in the time that was available to them. For example, they are more likely to say that there are just not enough staff, more likely to say that their workload is very heavy and more likely to have a high level of work stress. Those are the sorts of areas that obviously need to be targeted to attract and retain nursing staff in aged care.

Mr Ross —Could I perhaps add a further point to that. We can also provide a submission that we made to the House of Representatives inquiry into pay equity. The point we stressed in that was around the issue of occupational identity. For nursing staff to be attracted to aged care as well as nursing as a vocation, it is our strongly-held view that they need to be recognised as nursing staff working in aged care. There has been some considerable pressure over the years to introduce different sorts of generic classifications of work, to rebadge nursing staff and to call them something else or to blend nursing classifications with other classifications. That has the effect of devaluing the esteem in which those staff hold themselves and hold the work that they do. We certainly see that as counterproductive and that a strong nursing occupational identity in aged care is another incentive. It is perhaps more difficult to measure, but it is another incentive in addition to the skills mix and the wages, which are the bottom line.

CHAIR —In terms of compliance: having to have police checks and the amount of administrative work involved in spot checks, do you have a view or any submission to make on behalf of your union representatives? If you could give us some solutions, that would be helpful too.

Mr Ross —In terms of police checks, our view is that it was a reactive policy decision on the run in response to some assaults and other matters that had occurred. Obviously something needs to be done to stop those incidents occurring, but our experience has been probably similar to what Pam was saying previously in that in the event of an incident our members are stood down almost immediately. They are subjected to police investigations and often lose their employment out of what can generally turn out to be a dispute over a manual handling incident, where a resident has sustained an injury during a fall or a transfer and somebody has suggested that there was an excessive degree of force used; therefore, it constitutes an assault within the various definitions and it has to be reported. Our person is either dismissed, goes through disciplinary procedures or is suspended, and there is no further investigation into the actual handling strategies, the training et cetera that were used.

So we have picked up a few of those. Since the mandatory reporting has come in, we have had quite a few of those sorts of disputes at various facilities around the state. That would seem to be an unfortunate consequence of the mandatory reporting. In terms of the police checks, in Queensland, licensed nurses are subject to some police checking regimes anyway, and it is hard to see how they will marry up. There has been a cost to employees. Some employers met the cost of the initial checks and others did not. That is a further implication for employees as well.

CHAIR —Is that any different to the education system or child care?

Mr Ross —There are matters of degree in terms of what is and is not checked and that sort of thing, but I think the principle is largely the same.

Senator BOYCE —You talked about the complaints investigation system. Did I understand you to say that if a complaint highlights a workplace health and safety issue that is not really fed back into the system properly?

Mr Ross —Sorry; I was distinguishing between the complaints investigation system and the actual mandatory reporting. My understanding of the mandatory reporting is that it has to go to the police and it has to go to the department, and that is a bit different to the general complaints regime.

Senator BOYCE —Perhaps my terminology was wrong. If there is a mandatory report of an assault in a situation where someone has fallen whilst being transferred or whatever and it turns out to be more of a workplace health and safety issue, are you saying that that does not get fed back into system appropriately?

Mr Ross —It is probably a bit difficult to generalise across the board because these matters have a bit of a tendency to take their own path. By entering into a disciplinary process against an individual who is said to not have done their job properly—by whatever means—for the employer, the problem can be resolved by removing the individual rather than addressing some other matter. We have had material in the past about how staffing levels affect falls and those sorts of relationships. So there is an offshoot of the mandatory reporting that has resulted in individuals unnecessarily going through a disciplinary process. We have had people suspended for some considerable amount of time waiting for the conclusion of a police investigation which ultimately is not proceeded with.

CHAIR —Do you have some suggestions on how those parts of the compliance can be altered to protect the residents as well as give protection to the staff?

Mr Ross —There is a strict licensing regime for registered and enrolled nurses in place to protect the public safety and requires those people to acquit their responsibilities to certain standards. We are saying that that licensing regime should be extended to currently unlicensed carers—assistants in nursing. That would certainly go a long way to being able to satisfy the public on—

Senator BOYCE —What would be involved in licensing them?

Ms Garrahy —The Commonwealth government is introducing a national system for the licensing of healthcare professionals, to be introduced from 1 July next year. The initial professions to be included in the system are those 10 health professions, including nursing, that are currently licensed around the country. There are some principles established under that process which will be included in the legislation, we understand, that will outline how additional professions are added to that licensing system. So it would be a process of going through the National Registration and Accreditation Scheme system and submissions being made in relation to the need to license those currently unlicensed healthcare workers in aged care and other workers who provide direct nursing care in public hospitals, for example—in other words, people who are not licensed who deliver acute care as well as those in the aged-care industry. That would be the way it would happen. It would go through the national system.

Senator BOYCE —I am wondering how this works in with a nurse sitting possibly at the top of the pyramid and oversighting other people’s work if everyone has to be registered. But that is probably a discussion for another day.

Ms Garrahy —The benefits of registration include mandatory compliance with codes of ethics, codes of conducts and maintenance of particular levels of education and competency standards. They are the benefits of licensing.

CHAIR —Thank you.

Ms Garrahy —I did not speak to the members’ views on accreditation processes. Would you like me to touch on that briefly?

CHAIR —That would be great.

Ms Garrahy —I think it is fair to say that they have mixed feelings about the accreditation processes. Generally, the nursing staff want to be seen to be doing a very good job, because that is what they want to do. They are happy to have their work assessed by the accreditation agency; however, there are a number of frustrations in the system. For example, if they are working in an environment where their workloads are excessive and they do not have enough staff and the accreditation agency does a site audit and they get 44 out of 44, they feel frustrated and feel that the concerns that they may have expressed to the agency in those audits are not necessarily addressed or reflected in the outcome of the accreditation process. I think they are sometimes hesitant to report their concerns to the auditors for fear of reprisal. We understand that the auditors are required to tell the employer the classification level of any staff member who reports a concern. So the staff members are understandably concerned about possible recriminations if they report details of their concerns in some cases. That is generally the summary of their advice to us.

CHAIR —Thank you for your submission and for taking the time to appear before us today.

[2.47 pm]