Key Takeaways
- The Aged Care Act 2024 commenced 1 November 2025, replacing the Aged Care Act 1997 with a rights-based framework that extends accountability beyond registered aged care providers to the organisations delivering care on their behalf.
- GP practices and allied health businesses that deliver services to aged care residents under contract are "associated providers" under the new Act and carry direct Code of Conduct obligations, whether or not they are registered aged care providers.
- The Aged Care Code of Conduct applies to associated providers and aged care workers. Breaches carry civil penalties of up to 1,000 penalty units ($330,000) per contravention for body corporates, rising to 4,800 penalty units ($1,584,000) where death or serious harm results.
- AHPRA registration satisfies the Aged Care Worker Screening Check requirement for risk-assessed roles. GPs and registered allied health practitioners are covered. Unregistered support staff who regularly visit aged care facilities and interact with residents require a separate check.
- The Serious Incident Response Scheme (SIRS) expanded from residential care to also cover Support at Home providers from 1 November 2025. Priority 1 incidents must be reported to the Aged Care Quality and Safety Commission within 24 hours; Priority 2 within 30 calendar days.
- Seven strengthened Aged Care Quality Standards apply to registered providers in registration categories 4, 5, and 6 from 1 November 2025. Visiting clinicians are not directly audited against the Standards, but their care delivery forms part of how the facility meets the clinical care standard.
The Aged Care Act 2024 has been in force since 1 November 2025. For residential aged care facilities, the compliance transition was heavily flagged. For GP practices, allied health clinics, and other primary care providers that deliver services to aged care residents, the obligations are less commonly understood and often not acted on.
The Act introduces three changes with direct relevance to primary care providers. The "associated provider" concept creates explicit legal duties for organisations delivering aged care services on behalf of a registered provider. The expanded SIRS framework applies in settings where GPs and allied health practitioners regularly work. And the new worker screening rules require practices to confirm which staff need what check when they visit aged care facilities.
What Changed on 1 November 2025
The Act replaced the Aged Care Act 1997 with a framework reoriented around the rights of older Australians receiving funded care. Six registration categories group service types by care complexity and risk: home and community services; assistive technology and home modifications; advisory and support services; personal care and support in the home or community; nursing and transition care; and residential care including respite.
Providers deemed registered on 1 November 2025 received a notification from the Aged Care Quality and Safety Commission confirming their category. Seven strengthened Quality Standards replaced the previous eight from that date, applying to categories 4, 5, and 6. GP practices and allied health clinics contracting to deliver services to residents are not generally required to hold their own registration, but they carry obligations as associated providers.
Are You an Associated Provider?
An associated provider is an organisation that delivers funded aged care services on behalf of a registered provider, typically under a subcontract or services agreement.
A GP practice with a services arrangement to deliver consultations to residents at an aged care facility is an associated provider of that facility. An allied health business engaged under contract to deliver physiotherapy, occupational therapy, or speech pathology to residents holds the same status. The definition covers companies, partnerships, and sole traders operating through their own business structures.
The distinction between an "associated provider" (an organisation) and an "aged care worker" (an individual employed or directly engaged by a registered provider) matters. An allied health professional employed directly by an aged care facility is an aged care worker. The same professional contracting through their own business is an associated provider. Both carry Code of Conduct obligations. The difference is in how oversight responsibility is structured.
Registered providers cannot contract out their legal responsibilities. A facility that engages a GP practice to deliver services remains responsible for ensuring those services comply with the Act. The GP practice also holds direct Code of Conduct obligations.
Code of Conduct Obligations
The Aged Care Code of Conduct applies to registered providers, associated providers, and aged care workers. An associated provider must treat older people with dignity and respect, deliver safe and competent care, act with integrity, report safety concerns, and take no action that could harm or exploit a person receiving care.
Breaches carry civil penalties enforced by the Aged Care Quality and Safety Commission. For body corporates, a contravention carries up to 1,000 penalty units ($330,000). Where serious failure results in death, serious injury, or illness, the penalty rises to 4,800 penalty units ($1,584,000). The Commission can issue compliance notices, apply conditions to registration, or seek Federal Court penalty orders. Serious individual misconduct can result in banning orders preventing the individual from working in the aged care sector.
The Code applies to your organisation directly. It is not managed on your behalf by the aged care facility that engages you. Practices should confirm they have reviewed the Code requirements and have a governance process ensuring staff deliver care consistently with them.
Worker Screening: Who Needs What
The Act establishes an Aged Care Worker Screening Check for individuals in risk-assessed roles from 1 November 2025. A risk-assessed role involves: being a responsible person (such as a CEO or board member); direct delivery of aged care services to older people; or regular contact with older people that is more than incidental.
Three forms of screening satisfy the requirement:
- An Aged Care Worker Screening Check
- An NDIS Worker Screening Check clearance
- Current AHPRA registration
GPs and AHPRA-registered allied health practitioners, including physiotherapists, occupational therapists, speech pathologists, psychologists, and podiatrists, satisfy the screening requirement through their AHPRA registration. No separate Aged Care Worker Screening Check is needed.
The gap is with unregistered support staff. Practice assistants, clinic administrators, or health workers who visit aged care facilities and have regular direct contact with residents are in risk-assessed roles. They require either an Aged Care Worker Screening Check or a current NDIS Worker Screening Check. Enrolled nurses are AHPRA-registered and are covered.
Registered providers are responsible for verifying the screening status of workers delivering funded services on their behalf, including workers coming through an associated provider arrangement. Practices should audit which staff visit aged care settings and confirm their records are current.
SIRS: What to Know Before an Incident Occurs
The Serious Incident Response Scheme was introduced for residential aged care in 2021 and expanded to Support at Home providers from 1 November 2025.
The scheme covers nine categories of reportable incidents: unreasonable use of force; unlawful sexual contact or other sexual misconduct; psychological or emotional abuse; unexpected death; stealing or financial coercion; neglect; inappropriate use of restrictive practices; unexplained absence from care; and other serious incidents defined in the Aged Care Rules 2025.
Priority 1 incidents (those causing or likely to cause serious harm, death, or involving alleged sexual contact) must be reported to the Commission within 24 hours. Priority 2 incidents must be reported within 30 calendar days. Civil penalties for persistent non-compliance can reach $1,584,000 for body corporates.
The formal reporting obligation rests with the registered aged care provider, not the visiting clinician. But a GP or allied health provider who becomes aware of a reportable incident has both professional and Code of Conduct obligations to inform the facility promptly. Failure to do so creates liability under the Code. Practices should confirm they have a clear internal process for escalating incident awareness to the facility's compliance team.
For practices managing the overlap between aged care incident obligations and other mandatory reporting frameworks, our guide to healthcare data breach obligations in Australia covers the parallel requirements under the Privacy Act.
What Practices Should Do Now
Confirm your associated provider status
Review existing contracts, services agreements, or fee arrangements involving aged care residents. If any arrangement involves delivering services on behalf of a registered aged care provider, your practice carries Code of Conduct and governance obligations under the Act.
Audit staff screening
Identify every staff member who visits aged care settings and confirm their screening status. AHPRA-registered clinicians are covered. Non-registered staff with regular direct contact with residents require either an Aged Care Worker Screening Check or an NDIS Worker Screening Check.
Update your service agreements
Check whether current agreements with aged care facilities address the associated provider provisions in the new Act: Code of Conduct compliance obligations, notification requirements when arrangements change, and the facility's oversight rights.
Document your Code of Conduct governance
Store your Code of Conduct policy, staff orientation records, and incident escalation process in a form that can be provided to the facility or Commission if requested. The ClinicComply template library includes governance documentation templates relevant to aged care and clinical compliance. Track all active obligations using the compliance calendar.
For practices building clinical governance documentation for the first time, our guide to getting started with RACGP accreditation covers the governance systems that apply directly to aged care compliance. For a broader obligations overview, see our medical practice compliance checklist.
How ClinicComply Helps
Managing Aged Care Act obligations alongside RACGP accreditation, MBS compliance, and privacy requirements requires a system that keeps all active obligations visible and assigns responsibility clearly. ClinicComply's evidence tracking features let you document Code of Conduct policy adoption, worker screening records, and SIRS escalation procedures against the specific regulatory requirements they satisfy.
Task assignment and automated reminders ensure that policy reviews, screening renewals, and governance updates are flagged before they become overdue. For practices with staff visiting multiple facilities, the team management features coordinate obligations across your workforce without relying on spreadsheets.
See the full feature set at cliniccomply.com.au/features, or start a free 30-day trial at cliniccomply.com.au/signup.
Frequently Asked Questions
Does my GP practice need to register under the Aged Care Act 2024?
GP practices do not need to register as aged care providers unless they are directly delivering funded aged care services under a government funding agreement. However, if your practice delivers services to aged care residents under a contract with a registered aged care provider, your practice is an "associated provider" and carries direct Code of Conduct and governance obligations under the Act.
What is an associated provider under the Aged Care Act 2024?
An associated provider is an organisation that delivers funded aged care services on behalf of a registered aged care provider, typically under a subcontract or services agreement. A GP clinic or allied health business with a contract to deliver clinical services to residents at an aged care facility is an associated provider of that facility. The definition covers companies, partnerships, and sole traders delivering services under such arrangements.
Does AHPRA registration satisfy the Aged Care Worker Screening Check requirement?
Yes. Current AHPRA registration satisfies the screening requirement for workers in risk-assessed roles. GPs, registered nurses, enrolled nurses, physiotherapists, occupational therapists, speech pathologists, psychologists, and other AHPRA-registered practitioners do not need a separate Aged Care Worker Screening Check. Unregistered support staff who regularly visit aged care facilities and interact with residents require either an Aged Care Worker Screening Check or a current NDIS Worker Screening Check.
What is a risk-assessed role for aged care worker screening purposes?
A risk-assessed role is any position involving being a responsible person (such as a CEO or director), the direct delivery of aged care services to older people, or regular contact with older people that is more than incidental. Allied health professionals and GPs delivering clinical services to residents are in risk-assessed roles. Support staff who regularly accompany clinical staff into facilities and interact with residents are also in risk-assessed roles.
What does the Aged Care Code of Conduct require of my practice?
The Code requires associated providers to treat older people with dignity and respect, deliver safe and competent care, act with integrity and transparency, report safety and quality concerns, and take no action that could harm or exploit a person receiving care. The Code applies to your organisation directly. Breaches carry civil penalties of up to $330,000 per contravention for body corporates, rising to $1,584,000 if the breach results in death, serious injury, or illness.
What SIRS obligations apply to visiting GPs and allied health providers?
The formal SIRS reporting obligation rests with the registered aged care provider, not the visiting clinician. However, GPs and allied health providers who become aware of a reportable incident during the course of delivering services carry Code of Conduct duties to inform the facility promptly. The nine categories of reportable incidents include unreasonable use of force, neglect, unexpected death, psychological or emotional abuse, unlawful sexual contact, stealing or financial coercion, inappropriate use of restrictive practices, unexplained absence, and other serious incidents defined in the Aged Care Rules 2025.
What are the civil penalties under the Aged Care Act 2024 for associated providers?
Civil penalties for Code of Conduct breaches range from 150 penalty units ($49,500) to 1,000 penalty units ($330,000) for body corporate contraventions. Where a serious failure results in death, serious injury, or illness, the penalty rises to 4,800 penalty units ($1,584,000). The Aged Care Quality and Safety Commission enforces the Act and can issue compliance notices, apply conditions to a registered provider's registration, or seek penalty orders from the Federal Court. The Commission can also issue banning orders preventing individuals from working in the sector.
How should my practice update its service agreement with an aged care facility?
Service agreements with aged care facilities should confirm: your practice's commitment to comply with the Aged Care Code of Conduct; your notification obligation if the associated provider arrangement changes; the facility's right to maintain oversight and request compliance documentation; and worker screening verification procedures. Agreements predating 1 November 2025 that do not address these requirements should be reviewed and updated.
What are the seven strengthened Aged Care Quality Standards?
The seven Standards from 1 November 2025 are: (1) The Individual, (2) Governance, (3) Personal Care and Clinical Care, (4) Services and Supports for Daily Living, (5) Organisation's Service Environment, (6) Food and Nutrition, and (7) Feedback, Complaints and Residential Community. They replaced the previous eight and apply to registered providers in categories 4, 5, and 6. Visiting GPs and allied health providers are not directly assessed against the Standards, but the care they deliver forms part of how the registered facility demonstrates compliance with the clinical care standard.