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Support at Home (SaH) Program - Regulatory Context

Support at Home (SaH) Program - Regulatory Context

Last Updated: 2025-10-28 Status: Active Program (Go-Live: July 1, 2025) Regulatory Framework: Aged Care Act 1997, Support at Home Program Guidelines

Table of Contents

Overview

What is Support at Home?

Support at Home (SaH) is the Australian Government’s reformed aged care program that replaced the Home Care Packages (HCP) and Commonwealth Home Support Programme (CHSP) programs on July 1, 2025.

Program Goals:

  • Provide a more flexible, consumer-directed aged care system
  • Improve access to services through streamlined funding
  • Support older Australians to remain independent at home longer
  • Increase transparency in pricing and service delivery
  • Simplify administration for providers

Managed By

  • Services Australia: Government agency managing SaH funding, claims, and compliance
  • Department of Health and Aged Care: Policy and regulation
  • Aged Care Quality and Safety Commission: Quality standards and audits

Eligibility

Older Australians aged 65+ (50+ for Aboriginal and Torres Strait Islander peoples) who:

  • Have been assessed by Services Australia as needing support
  • Require assistance to live independently at home
  • Meet the aged care means test

Program Structure

Service Categories

Support at Home services are organized into Service Groups, Service Types, and Services:

Service Groups (SERG)

  1. SERG-0001: Home Support

    • Personal care, domestic assistance, social support
    • Meals, transport, allied health
    • Most commonly used service group

  2. SERG-0002: Assistive Technology (AT)

    • Equipment and devices to support independence
    • Mobility aids, communication devices
    • Subject to caps and approval thresholds

  3. SERG-0003: Home Modifications (HM)

    • Physical changes to the home environment
    • Ramps, grab rails, bathroom modifications
    • Subject to caps and approval thresholds

  4. SERG-0004: Care Management

    • Care coordination and planning services
    • Case management

  5. SERG-0005: End of Life Pathway (EL)

    • Specialized support for end-of-life care
    • Higher funding allocation

  6. SERG-0006: Restorative Care Pathway (RC)

    • Short-term intensive support
    • Goal-oriented rehabilitation

Assessment & Planning

  1. Assessment: Services Australia conducts needs assessment
  2. Budget Allocation: Funding assigned based on assessed needs
  3. Service Planning: Care plan developed with care coordinator
  4. Service Delivery: Providers deliver services
  5. Claiming: Providers submit invoices to Services Australia
  6. Payment: Services Australia processes claims and pays providers

Key Changes from HCP

Major Differences

AspectHome Care Packages (Old)Support at Home (New)
Program Structure4 levels (HCP 1-4)Flexible, needs-based budgets
Budget AllocationFixed annual amount by levelQuarterly, based on assessed needs
Funding ModelPackage subsidyActivity-based claiming
Fee StructurePercentage-based (15-17%)Usage-based loading fees (10%)
Service CategoriesUnstructuredStructured service groups (SERG)
ClaimingProvider holds fundsDirect claiming from Services Australia
Consumer ContributionsIncome-tested care feeIncome-tested care fee (similar)
Pricing TransparencyLimitedRequired price lists and transparency
RolloverComplex, provider-managedAutomatic, SA-managed (60 days)

What This Means for Trilogy Care

Before (HCP Model)

  • TC received package subsidy upfront
  • TC held and managed client funds
  • TC charged management fees as % of subsidy
  • Annual budget cycles
  • Complex rollover management

Now (SaH Model)

  • TC claims for services as delivered
  • Services Australia pays directly
  • TC charges 10% loading fee per service
  • Quarterly budget allocations
  • Automatic rollover by SA (60 days post-quarter)

Fee Structure & Models

Loading Fee Model

Support at Home uses a usage-based loading fee structure instead of fixed percentage fees.

Fee Components

For each service delivered:

Total Package Debit = Supplier Cost + TC Fee + CC Fee (if applicable)

Example: 2 hours of house cleaning at $50/hour

  1. Self-Managed Model:

    • Supplier Invoice: $100
    • TC Loading Fee (10%): $10
    • Total Package Debit: $110

  2. Self-Managed PLUS Model (with Care Coordinator support):

    • Supplier Invoice: $100
    • CC Loading Fee (20% of supplier): $20
    • TC Loading Fee (10% of supplier + CC): $12
    • Total Package Debit: $132

Fee Rates

Fee TypeRateApplied ToWho Receives
TC Management Fee10%Supplier cost + CC feeTrilogy Care
Care Coordinator Fee20%Supplier cost onlyCare Coordinator (SM+ only)
Supplier PaymentInvoice amountService deliveredService Provider

Fee Allocation Rules

Fees are deducted from specific funding streams in priority order:

  1. EL (End of Life) - Highest priority
  2. ON (Ongoing) - Primary funding
  3. RC (Restorative Care)
  4. CU (Commonwealth Unspent) - No client contributions
  5. HC (Home Care Account) - Client funds
  6. VC (Voluntary Contribution) - Client voluntary payments

See config/support-at-home.php for allocation rules per service group.

MYOB Accounting Structure

The fee-inclusive model requires specific accounting treatment:

Bill Record Structure:

  • Line items: Fee-inclusive amounts → Client Balance accounts (by funding stream)
  • TC Loading: Negative line item → Revenue account (e.g., 6850)
  • CC Loading: Negative line item → Payable account (e.g., 6600)
  • GST: Separate line item → GST account
  • Bill Total: Supplier invoice amount (what they get paid)

See services-australia-api.md for API expectations.

Reference: support-at-home---myob-structure.md

Funding Streams

Core Funding Streams

CodeNameDescriptionExpirableContributions Apply
ONOngoingPrimary home support fundingYes (quarterly)Yes
ATAssistive TechnologyEquipment and devicesNoYes
CMCare ManagementCoordination servicesNoNo
ELEnd of LifePalliative/EOL supportNoNo
HMHome ModificationsPhysical home changesNoYes
RCRestorative CareShort-term rehabilitationNoNo
ASAssistive Tech (Specified)High-value AT itemsNoYes
CUCommonwealth UnspentRolled-over govt fundsNoNo
HCHome Care AccountClient private fundsNoN/A
VCVoluntary ContributionAdditional client fundsNoN/A

Funding Allocation Rules

Different services can be paid from different funding streams:

Home Support (SERG-0001): EL, ON, RC, CU, HC, VC Assistive Technology (SERG-0002): AT, AS, CU, HC, VC Home Modifications (SERG-0003): HM, CU, HC, VC

Quarterly Budgets

  • Funding allocated per 13-week quarters
  • Quarters defined by Services Australia (Q1, Q2, Q3, Q4)
  • Budget allocation reviewed quarterly based on needs
  • Underspend automatically rolls over (60 days grace period)

Underspend Management

Trilogy Care monitors underspend and alerts at:

  • 31-45 days (33% through quarter): First alert
  • 61-75 days (66% through quarter): Second alert
  • 76-90 days (85% through quarter): Final alert

Purpose: Ensure clients utilize their budget before rollover period expires.

Regulatory Requirements

Pricing Transparency

Providers must:

  1. Publish price lists for all services
  2. Clearly display TC management fees
  3. Provide itemized statements showing:
    • Service delivered
    • Provider cost
    • TC management fee
    • CC fee (if applicable)
    • Funding stream used
    • Remaining balance per stream

Service Standards

All services must meet:

  • Aged Care Quality Standards (8 standards)
  • Charter of Aged Care Rights
  • Serious Incident Response Scheme (SIRS) requirements
  • Commonwealth Home Support Programme Guidelines

Claims & Invoicing

  1. Invoice Timing: Claims must be submitted within 60 days of quarter end
  2. Late Submissions: Require justification and evidence
  3. Service Verification: Proof of service delivery required
  4. Attachments: Required for:
    • Late submissions
    • High-value items (AT, HM)
    • Prescribed items
    • Loaned equipment

Compliance & Audits

Services Australia may:

  • Request evidence of service delivery
  • Audit claims and payments
  • Recover overpayments
  • Suspend claiming privileges for non-compliance

Timeline & Milestones

Key Dates

DateMilestone
July 1, 2025Support at Home program commenced
Oct 2025SaH APIs available for testing
Nov 1, 2025Government CSV portal expected to be available
Q1 2026First SaH quarterly budget cycle complete
June 30, 2026HCP to SaH transition complete

Transition Period

  • July 1 - Dec 31, 2025: Transition period for existing HCP clients
  • HCP clients: Gradually moved to SaH budgets
  • CHSP clients: Integrated into SaH framework
  • New clients: Start directly on SaH from July 1, 2025

Impact on TC Portal

Required Changes

1. Fee Model (✅ Completed)

  • Migrate from percentage-based to usage-based loading fees
  • Calculate TC fee (10%) and CC fee (20%) per service
  • Apply fees to correct funding streams

2. Budget Management (🏗️ In Progress)

  • Support quarterly budget allocations
  • Track spending per quarter per funding stream
  • Implement underspend alerts (33%, 66%, 85%)
  • Handle automatic rollover from SA

3. Invoicing & Claiming (🏗️ In Progress)

  • Generate invoices in SA API format
  • Support CSV export for government portal
  • Track invoice status (OPEN, SUBMITTED, CLAIMED, COMPLETED)
  • Handle late submission workflows

4. Service Classification

  • Map TC services to SA service IDs (SERV-XXXX)
  • Support service groups (SERG), service types (SERT)
  • Implement conditional field logic for AT/HM
  • Support wraparound services and health professional classification

5. Statements & Reporting

  • Show fee-inclusive amounts on client statements
  • Break down TC fee vs CC fee vs supplier cost
  • Display funding stream balances per quarter
  • Generate SA-compliant reports

6. Compliance

  • Enforce 60-day claiming deadline
  • Collect evidence for late submissions
  • Support attachment uploads (PDF)
  • Maintain audit trail for all SA interactions

Technical Architecture

Key Components:

/domain
  /Funding
    - FundingStream (model)
    - Funding (model)
    - Quarter (model)
  /Budget
    - BudgetPlan (with quarterly allocations)
    - BudgetPlanFundingStream
  /Billing
    - Bill (invoice)
    - BillItem (service line item)
    - ServicesAustraliaInvoice (SA API representation)
  /Integration
    - ServicesAustraliaApiClient
    - InvoiceExportService

Jobs:

  • SyncServicesAustraliaInvoiceStatusJob - Poll SA for invoice status updates
  • ExportInvoicesToSAHCSVJob - Generate CSV for government portal
  • QuarterEndRolloverJob - Process quarter-end rollover
  • UnderspendAlertJob - Send alerts at 33%, 66%, 85%

Events (Event Sourcing):

  • BudgetPlanFundingStreamAdded
  • BudgetPlanFundingStreamUpdated
  • FundingSyncedFromServicesAustralia
  • InvoiceSubmittedToServicesAustralia
  • InvoiceStatusUpdatedFromServicesAustralia

Data Requirements

Portal Data Captured

TC Portal must capture:

Invoice Level:

  • Service provider ID (SA ID)
  • External reference (TC invoice ID)
  • Invoice status

Item Level (per service delivered):

  • Care recipient ID (SA package ID)
  • Service ID (from SA service list)
  • Delivery date
  • Quantity (in 0.25-hour increments)
  • Price per unit (supplier rate, excl. fees)
  • Unit type (hours, trip, item, bill, voucher, meal)
  • Funding source (ON, RC, EL, etc.)

Conditional Fields (based on service type):

  • Item/wraparound classification
  • Item description code (for AT/HM)
  • Health professional type (for clinical services)
  • Purchase method (purchased/loaned for high-value AT)
  • First payment flag (for HM)
  • Late submission reason & justification

Attachments:

  • Evidence for late submissions
  • Prescriptions for prescribed items
  • Quotes/invoices for loaned equipment

See services-australia-api.md for full field mapping.

Service Provider Requirements

For Suppliers

Suppliers submitting invoices must:

  1. Be registered with Services Australia (have provider ID)
  2. Meet quality standards (NDIS or equivalent)
  3. Have valid insurances:
    • Public liability
    • Professional indemnity
    • Workers compensation
  4. Comply with pricing guidelines
  5. Deliver services as per care plan

For TC Portal

  1. Verification: Validate supplier credentials before onboarding
  2. Pricing: Ensure rates align with SA price schedules
  3. Documentation: Collect and store compliance documents
  4. Audit Trail: Maintain complete history of all supplier interactions

Reference Materials

Service Lists

Services Australia provides:

  1. Service List API: All available services (SERV-XXXX codes)
  2. Item List API: AT/HM item codes and descriptions
  3. Wraparound List API: Wraparound service codes
  4. Health Professional List API: Health professional types
  5. Funding Source List API: Valid funding sources per service

These lists should be:

  • Cached locally in TC Portal
  • Refreshed daily via scheduled job
  • Used for validation during service planning and invoicing

Government Resources

Risks & Considerations

Key Risks

RiskImpactMitigation
SA API DowntimeCannot submit claimsCSV export fallback, queue for retry
Data Mapping ErrorsClaim rejectionsValidation before submission, test coverage
Fee MiscalculationClient overcharge/underchargeComprehensive unit tests, financial reconciliation
Late SubmissionLost revenueAutomated alerts, grace period monitoring
Compliance BreachProvider suspensionRegular audits, automated validation

Contingency Plans

  1. API Failure: Use CSV export to government portal
  2. Validation Errors: Manual correction workflow with admin approval
  3. Payment Delays: Track outstanding claims, follow up with SA
  4. System Changes: Monitor SA announcements, maintain flexible mapping layer

Future Enhancements

Planned

  1. Real-time Budget Sync: Webhook integration with SA for instant balance updates
  2. Predictive Analytics: Forecast underspend, recommend service adjustments
  3. Automated Service Planning: AI-generated budgets based on needs assessment
  4. Provider Marketplace: Match clients with providers based on SaH service requirements
  5. Compliance Dashboard: Real-time view of SA claiming status, error rates, payment timelines

Under Consideration

  1. Direct Client Portal: Allow clients to view SA statements directly
  2. Mobile App: Field workers capture service delivery in real-time
  3. Automated Reconciliation: Match SA payments to TC Portal invoices
  4. Advanced Reporting: SA-compliant reports for financial audits

Glossary

TermDefinition
SaHSupport at Home program
SAServices Australia (government agency)
HCPHome Care Packages (predecessor program)
CHSPCommonwealth Home Support Programme
SERGService Group (e.g., SERG-0001 for Home Support)
SERTService Type (e.g., SERT-0001 for Home Maintenance)
SERVService code (e.g., SERV-0001 for House Cleaning)
NAPSNational Approved Provider System
ATAssistive Technology
HMHome Modifications
TCTrilogy Care
CCCare Coordinator
SM+Self-Managed PLUS (with coordinator support)
Loading FeeUsage-based management fee (10% for TC)

Maintained by: Product & Development Teams Questions?: Contact product owner or refer to Services Australia provider documentation Last Reviewed: 2025-10-28