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Let's take reporting seriously

Authored 19 July 2021

Reporting is not just ‘red tape’ – it is an essential part of clinical governance. Why? Because unless we observe and assess care outcomes and experiences on an ongoing basis - which reporting enables – we cannot effectively identify risks, emerging risks, or areas for improvement.

One example is reporting an adverse event following immunisation (AEFI), which is broadly defined as ‘any negative reaction that follows immunisation.’ By reporting an AEFI, it enables the Therapeutics Good Administration to:

(i) Understand the safety profile of new vaccines;

(ii) Monitor the incidence and trends of adverse incidents nationally; and

(iii) Identify issues relating to all levels of the vaccination program (ie. manufacture, storage, delivery and administration).

Particularly in the context of the COVID-19 pandemic, where new vaccines are being rolled out quickly, such reporting is crucial to the ongoing assessment of vaccine safety, as well as public confidence.

The role of adverse incident reporting in clinical governance can also be seen in Australia’s disability sector. Under the National Disability Insurance Scheme Act 2013 (Cth), specified ‘reportable incidents’ (and allegations thereof) must be notified to the National Disability Scheme Commission, even where they have been acted upon and responded to. This represents one aspect of incident management, prescribed under a specific regulatory scheme.

However, reporting goes beyond incident management alone and informs ongoing risk assessment. It is, therefore, an important tool in the prevention of harm. By consistently reporting relevant and appropriate indicators, we can identify the risk of an adverse incident before it materialises. In addition, reporting facilitates continuous improvement by allowing us to monitor, measure, compare and review aspects of care provision, care experiences, and care outcomes.

The aged care National Aged Care Mandatory Quality Indicator Program (QI Program) is an example of such reporting. Under this program, residential aged care providers must report a range of parameters (rather than ‘incidents’) on a quarterly basis. These are considered to be ‘relevant to indicating the quality of the residential care'.

The QI Program’s objectives are ‘for providers to have robust, valid data to measure and monitor their performance and support continuous quality improvement in the care they provide to aged care recipients’ and ‘over time, to give consumers transparent information about quality in aged care to assist decision-making.’ Therefore, not only does the QI Program facilitate the collection and assessment of data to inform continuous improvement, but it also supports consumer-centred care - which of course is central to clinical governance, not least in aged care.

As in disability, aged care providers must also report a range of incidents to the Aged Care Quality and Safety Commission, under the Serious Incident Response Scheme (SIRS). These are very broadly defined and include the unreasonable use of force, physical or emotional abuse and neglect. Further, there need not be an actual ‘incident’ – under SIRS, a mere allegation or suspicion will suffice to trigger the reporting obligation. Therefore, we may expect reporting under SIRS to inform continuous improvement in aged care through reporting of consumer perception, and hence support consumer-centred care.


https://www.health.gov.au/health-topics/immunisation/health-professionals/reporting-and-managing-adverse-vaccination-events (accessed on 19/7/2021)

https://www.health.gov.au/health-topics/immunisation/health-professionals/reporting-and-managing-adverse-vaccination-events (accessed on 19/7/2021)

https://www.ndiscommission.gov.au/document/2226 (accessed on 19/7/2021).

Section 73Z, National Disability Insurance Scheme Act 2013 (Cth).

NDIS Quality and Safeguards Commission Fact Sheet, ‘Incident management and reportable incidents: incident reporting, management and prevention’, at https://www.ndiscommission.gov.au/document/2226 (accessed on 19/7/2021)

Accountability Principles 2014 (Cth), section 26.

National Aged Care Mandatory Quality Indicator Program, Manual 2.0 – Part A. Accessed at: https://www.health.gov.au/resources/publications/national-aged-care-mandatory-quality-indicator-program-manual (accessed on 19/7/2021)

Aged Care Quality Standards

https://www.agedcarequality.gov.au/sirs (accessed on 19/7/2021)

Aged Care Legislation Amendment (Serious Incident Response Scheme and Other Measures) Act 2021 (Cth).

‘Serious Incident Response Scheme – Guidelines for residential aged care providers (June 2021)’, accessed at: https://www.agedcarequality.gov.au/resources/serious-incident-response-scheme-guidelines-residential-aged-care-providers (accessed on 19/7/2021)

Aged Care Legislation Amendment (Serious Incident Response Scheme and Other Measures) Act 2021 (Cth), Schedule 1, Part 1.

Aged Care Act 1997 (Cth), section 54-3 as amended.

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