The aged care system in Australia provides subsidised and fully funded aged care services to older persons. Whether this involves basic care at home, comprehensive care in a residential setting, or something in between, these services are critical for supporting the dignity and wellbeing of older people. To access aged care services, older persons are required to undergo an aged care needs assessment (needs assessment). A needs assessment works out what type of help an older person needs and what types of aged care services they are eligible for.
Currently, this occurs through the Single Assessment System (SAS), which is administered by the System Governor under the Aged Care Act 2024 (Cth) (the Act). The System Governor is the Secretary of the Department of Health, Disability and Ageing (the Department). The SAS came about because of recommendations 28 and 48.2(b) of the Royal Commission into Aged Care Quality and Safety (March 2021).
The Single Assessment System (SAS)
Our focus in this investigation related to two important components of the SAS, the Integrated Assessment Tool (the IAT) and the SAS workforce, both explained below. What is the IAT? The Aged Care Rules 2025 (the Rules), made under the Act, prescribe the IAT as the assessment tool to be used for home care assessments. The Rules define the IAT as the IAT “published by the Department”. Our investigation has focussed on the digital assessment application that assessors are required to use for all needs assessments.
The application incorporates three key components: • the assessment questions that an assessor uses to collect information from an older person, • one of 2 algorithms5 that makes automated decisions about eligibility through classification and priority based on that information, and • support planning, where the assessor recommends specific aged care services for an older person. Of these three components, only the assessment questions have been published by the Department. In our view, the assessment questions and the algorithm are integrally connected, not least because it is the algorithm that makes the actual decisions (or assessments) about eligibility.
Following completion of the assessment questions, the IAT’s algorithm makes one of three automated decisions (automated IAT decision): Two different algorithms are used to determine a person’s classification (funding) level and their priority category. The classification algorithm determines an older person’s ongoing home support funding level through the Commonwealth Home Support Program or Support at Home. The prioritisation algorithm determines an older person’s priority category for Support at Home funding. • that the older person is eligible to access aged care services under the Commonwealth Home Support Program (the CHSP), OR • that the older person is eligible to access aged care services under the Support at Home program (the SAH program) and if so, their funding level and priority category, OR • that the older persons is not eligible to access the CHSP or the SAH program. Currently, under the law, these automated decisions cannot be overridden and changed, even if they are clinically inappropriate. These automated decisions are made by the IAT’s algorithm. Put another way, a human decision-maker does not decide the 3 key matters described above. The CHSP and the SAH program are home- based aged care programs. The CHSP is designed to provide entry-level care for older persons who need a low level of support to live independently and safely, while the SAH program is designed to support older persons with more complex or intensive care needs. ... The other component of the SAS that this investigation examined, the SAS workforce, comprises the assessment providers that are contracted by the Department to undertake functions delegated by the System Governor including needs assessments using the IAT. There are currently 22 assessment providers in Australia (assessment providers can be private sector organisations or state government bodies). Importantly, assessment providers also make approval decisions about what aged care services an older person can access.
The role of the assessment delegate is to decide whether to approve the older person’s access to the aged care services recommended within the support plan. As part of administering the SAS, the Department oversees the work of assessment providers, including undertaking assurance activities, managing complaints about their performance and creating operational rules that they are required to follow under their contract. It also reviews the decisions made by assessment providers through an internal review mechanism and manages the My Aged Care website and call centre, which serve as the front door for aged care services in Australia.
Why we investigated
Since the introduction of the SAS, a range of concerns have been raised by the public and in different forums about its operation, and in particular about how the IAT works. These include, for example: • that communication from assessment providers is often poor and needs assessments can be difficult to arrange, • that waiting times for needs assessments can be substantial, • that review processes can be slow, • that there are insufficient assessors to meet demand and those that are available may lack appropriate training and qualifications, • that the IAT significantly diminishes the role of clinical expertise, • that the automated IAT decision could not be changed once an assessment was finalised, even if it is considered unsuitable, and • that the algorithm: o lacks transparency, and o risks significantly underassessing an older person’s care needs, resulting in outcomes that are clinically inappropriate. In April 2026, in relation to this last point, the Australian and New Zealand Society for Geriatric Medicine said the following: ‘[we are] concerned that, in its current form, the [IAT] risks systematically under-identifying frailty, functional vulnerability and clinical complexity in older people. There are also broader concerns regarding the reliability and consistency of assessments.
Oversight of the Single Assessment System variability in assessor experience, limited clinical guidance within the [IAT] and a highly structured format may contribute to inconsistent outcomes and reduce the ability to capture clinical complexity. These factors raise risks for both under and over classification of need.’ Based on these concerns, our complaint information and preliminary inquiries with the Department, we decided to investigate. We were concerned that assessment providers were not being reasonably oversighted by the Department and that the IAT and its associated decision-making framework could be leading to unfair outcomes and undermining public confidence in the assessment system.
We investigated the actions of the Department under section 5(1)(b) of the Ombudsman Act 1976 (Cth) (Ombudsman Act). The investigation was designed to answer the following questions: • Does the IAT and its associated decision-making framework have the potential to undermine public confidence in the administration of a fair and consistent assessment system? (question one) • Given the critical importance of assessments as the input to the IAT, is the Department reasonably oversighting the performance of assessment providers? (question two)
Our findings
The Ombudsman has formed the opinion that: • under section 15(1)(a)(ii) of the Ombudsman Act, the actions of the Department in its administration of the SAS, including the implementation of the IAT, have been unreasonable, and • under section 15(2)(f) of the Ombudsman Act, the Department should, as soon as practicable, consider the recommendations in this report and work towards implementing them.
A note about the operation of the algorithm and our findings
Our investigation did not assess the clinical appropriateness of the algorithm. The deficiencies that we identified in the design and development of the IAT do however raise legitimate concerns about the reliability of the results it produces. Thus, while our findings do not establish that the algorithm in fact produces clinically inappropriate outcomes, taken together they raise serious questions about its suitability and underscore the need for independent clinical review, as recommended below.
Findings for question 1 – summary
In our view, based on the matters below, the IAT and its associated decision-making framework do not merely have the potential to undermine public confidence in the administration of a fair and consistent assessment system. Rather, a reasonable person would, in our view, lack confidence that the system is in fact fair and consistent.
• There is a contradiction in allowing assessor expertise and judgement to inform the inputs into the IAT but not to consider the appropriateness of the outcomes. Different assessors may reasonably form different views about the same older person, leading to different inputs and therefore different IAT scores. Because the inputs are not objective, it is incorrect for the Department to say that the resulting automated IAT decisions involve only objective and binary methodology.
• There is no public information available that meaningfully explains how the algorithm converts inputs into outcomes. Without this, the IAT is a technological black box.
• The Department has not complied with Recommendations 17.1 and 17.2 of the Royal Commission into the Robodebt Scheme regarding transparency of government automated decision-making. • Information provided by the Department to the public suggests that key trials and consultation over several years directly supported the IAT and its associated decision-making framework in its current form, but that is not correct. Those trials and consultation related to earlier versions of the IAT and earlier legislation.
• The Department implemented the IAT in its current form without any meaningful risk assessment, evaluation or analysis, despite the obvious risks that would arise with deterministic automated decision-making (i.e. automated decision-making that does not allow for human override and change).
• While it appears the IAT was built with an override mechanism, there is no mechanism at law to override and change automated IAT decisions that are considered clinically inappropriate, notwithstanding that these decisions can have serious implications for an older person’s health, independence and living circumstances.
• In our view, the Department did not, and may still not, understand key components of the legal framework it created, nor did it understand what legal framework it was meant to create. This had serious consequences, including that up until the introduction of the Act and the Rules in October 2025, the Department had been incorrectly advising assessment providers and the public that automated IAT outcomes could be changed. This is despite the fact that there was no mechanism in the Act or the Rules to change outcomes.
• Reasons for decisions, including internal review outcomes, may in many cases not provide meaningful information to those who have sought the review. If they are not able to understand the basis of the decision, they will not know whether it is a correct assessment of their circumstances or not, and therefore whether they should seek external review or not.
Findings for question 2 – summary
In our view, based on the matters below, the Department has not been reasonably oversighting the performance of assessment providers. The Department should be doing more in a range of areas to improve the operation of the SAS.
• Assessment provider performance in relation to KPIs has been falling short, in many instances to a significant extent, across important areas that bear on service delivery and quality.
• Despite the fact that assessor performance is a critical component of the SAS, as it is individual assessors who input information into the IAT, the Department undertakes a limited role in relation to checking compliance with learning requirements. It does not, for example, conduct assurance activities aimed at ensuring assessors hold appropriate qualifications, have the appropriate experience and have completed required mandatory training. The workforce pressures faced by assessment providers give rise to a material risk that learning requirements, which underpin the quality of the entire framework, are missed, unmet or otherwise not complied with. Exacerbating matters further, the Department’s online learning environment does not contain any safeguards or mechanisms to protect the integrity of online training.
• The Department undertakes a limited role in relation to oversighting how assessors use the IAT and its quality assurance approach appears not to extend to matters beyond IAT use, despite the importance of other areas within the SAS.
• The Department does not have a framework in place to draw insights from complaints to inform systemic assurance activities in relation to assessment provider performance.
• The Department’s flexible approach to the enforcement of contractual obligations was implemented without compensating controls. Despite accountability mechanisms being available to the Department for some time (for example, the ability to require an assessment provider to enter into a remediation plan to address non-compliance), these have only recently come into use, and timing of their use raises concerns about the Department’s planning and communication.
• Information that the Department provides about the complaints process omits important information about how complaints are handled, likely timeframes and possible outcomes. This creates a risk that older persons may misunderstand the process or not pursue legitimate complaints.
• Complaints are not used as a primary source of information for broader assurance activities, limiting the Department’s ability to identify systemic issues. On 16 October 2026, the government announced that it will introduce a new escalated pathway to provide an additional review process for certain aged care assessment decisions. We recognise this as a positive step towards strengthening human oversight and will monitor the implementation of the new pathway. We acknowledge that since we commenced our investigation, a rapid review was announced, and the Department has also made improvements in several areas. These include shorter priority wait times, more timely data collection, and provision of information to the public.
We welcome the Department's publication of information on 6 October 2026 – after the Department had responded to our draft report in the procedural fairness process - about the IAT classification algorithm, the business rules underpinning the IAT and plain English explanatory material. This is important, given the significance of the algorithm in determining older people's access to aged care services. However, we are disappointed this critical information was not made publicly available sooner. As recently as August 2026, there was no publicly available information that meaningfully explained how the algorithm converted assessment inputs into classification outcomes. While the publications released by the Department on 6 October 2026 represent a positive step towards greater transparency, it remains to be established whether they provide sufficient detail to enable independent parties to reproduce the outcomes of the assessment process to ensure equitable access to aged care services. We therefore consider it would be premature to conclude that our concerns in this regard have been addressed.
Recommendations
Recommendation 1 The government, with the assistance of the Department, introduces a bill to amend the Aged Care Act 2024 (Cth) (the Act) to allow assessment delegates to substitute their own decision for that of an automated IAT decision in appropriate circumstances.
Recommendation 2
As far as necessary to give effect to the above recommendation, the Minister amends the Aged Care Rules 2025 (Cth) (the Rules) and separately, either the Minister or the Secretary as the designated System Governor of the aged care system provides meaningful policy guidance to assessment delegates about applying any test for substitution.
Recommendation 3 The Department undertakes a comprehensive review of the Act and the Rules as they relate to the needs assessment process, including use of the IAT, to identify legal defects, inconsistencies, ambiguities or unintended consequences and, using that information, address those issues in a timely way.
Recommendation 4 That any proposed amendments to the Act, the Rules and the algorithm be preceded by and informed by meaningful consultation with the public.
Recommendation 5 In accordance with recommendation 17.1 of the Royal Commission into the Robodebt Scheme, the Department: • develops and publishes a fact sheet, in plain language, that informs the public about how the IAT works and the existence of automated decision-making, • develops and publishes a fact sheet, in plain language, that informs the public about how internal and external merits review operates for SAS decisions and what limitations exist for those seeking review, and • makes the business rules underpinning the algorithm available to the public and in doing so, provides a plain language explanation of how these operate.
Recommendation 6 The Department more effectively oversights the performance of assessment providers by undertaking: • significantly more proactive audits/reviews of IAT usage, and • consistent assurance activities in relation to: o compliance with learning requirements, o compliance with quality assurance requirements outside of IAT usage, and o compliance with meeting key performance indicators.
Recommendation 7 The Department amends its approach to receiving and dealing with complaints about assessment provider performance by developing a new complaints framework that: • outlines how complaints will be dealt with, by who and by when, and • implements a method to analyse complaints and use the resulting insights to inform the planning and prioritisation of systemic assurance activities.
Recommendation 8 The Department undertakes a root cause analysis to determine the underlying factors that contributed to the findings in this report, including any other issues identified by the Department, and in doing so uses the results to implement corrective actions.
Recommendation 9 The Department undertakes a comprehensive review of the business rules underpinning the algorithm.
Recommendation 10 While noting that the Auditor-General is an independent statutory officer, and also noting that the implementation and delivery of the SAS is a potential audit listed on the Australian National Audit Office's (ANAO) 2026-27 audit work plan, the ANAO consider undertaking a performance audit in relation to the implementation of the SAS and the design of the IAT, and in doing so, assesses whether the Department’s use of public resources was efficient, economical and ethical.
