Care minutes are now audited: what providers must fix

Care minutes reporting has moved from a self-declared figure to an audited one. From the 2025-26 financial year, all residential aged care providers must submit a Care Minutes Performance Statement audited by a registered company auditor, lodged as part of the Aged Care Financial Report due 31 October 2026.

For most Tasmanian providers the target itself is familiar. What has changed is the standard of proof. A number that was previously assembled from rostering software and signed off internally now has to survive an assurance engagement under ASAE 3000, the same standard applied to other non-financial assurance work.

The statement is an assurance engagement, not a return

An audit tests the evidence behind the number rather than the number itself. The auditor works from the underlying records: rosters, timesheets, payroll classifications and occupied bed days. If the reported minutes cannot be traced back to source records that agree with each other, the opinion reflects that.

The Department has published audit report templates covering unmodified opinions alongside qualified, adverse and disclaimed ones. That is a reasonable signal that not every statement is expected to come back clean. A qualified opinion is not a sanction in itself, though it does put a provider’s reporting in front of the Department with a question already attached to it. The same move from providing care to evidencing it runs through the strengthened Standards, which proving quality, not just providing it works through in detail.

Classification errors are the most common weak point

Care minutes count direct care delivered by registered nurses, enrolled nurses and personal care workers. The registered nurse component is counted separately. Where a facility has staff working across roles, or where an EN is rostered on a line coded as a care worker, the split between total minutes and RN minutes can drift from what payroll shows.

Small homes with flexible rostering are the most exposed. One person covering two functions is a normal week rather than an exception, so the mapping between a roster line and a counted classification has to be deliberate. Where that mapping lives only in the roster clerk’s head, an auditor will find it difficult to test.

A mismatch with quarterly reporting has a funding consequence

Where the audited statement reports different care minutes from those already lodged in the Quarterly Financial Report, the Department may recalculate the care minutes supplement. That makes the reconciliation between quarterly and annual figures worth doing before the auditor arrives. A correction found in October is a funding adjustment as well as a compliance note.

The reconciliation is rarely difficult. It is usually just late. Quarterly figures are prepared under time pressure by whoever is available, while the annual statement is prepared with more care, so the two can diverge without anyone doing anything wrong. Running the comparison in August gives a provider two months to work out which version is right.

The number was always reportable. What is new is that someone independent now has to agree with it.

The targets have not moved

The sector-wide requirement remains 215 minutes of direct care per resident per day, of which 44 minutes must be delivered by a registered nurse. The target is averaged across the home and weighted by resident acuity, so a higher-acuity home carries a higher effective requirement. Homes in rural and remote areas can apply for an exemption from the 24/7 registered nurse requirement, though that sits separately from the care minutes targets.

Providers already meeting their targets have no new operational obligation here. They have a new evidentiary one. The distinction matters for how the work gets resourced: this is a finance and rostering data exercise before it is a clinical one.

What to check before October

• Reconcile the four quarters of reported care minutes against the annual figure now, while corrections are still cheap
• Confirm every staff member counted in the RN component held current registration for the whole period claimed
• Check that agency and contracted hours are captured in both minutes and labour costs
• Verify occupied bed days against resident records rather than against the rostering system’s assumption
• Appoint the auditor early, since ASAE 3000 engagements across the sector will cluster around the same deadline
• Document how each roster line maps to a counted classification, so the logic does not depend on one person’s memory

The workforce question underneath the audit

An audited statement makes a staffing gap visible in a way an internal spreadsheet does not. A home carrying vacant RN lines through part of the year will see that reflected in its RN minutes. Now it will also see it reflected in an auditor’s opinion, which connects the reporting deadline to the recruitment plan more directly than most compliance obligations do.

The case for stable permanent rosters set out in national minimum staffing levels applies here too, because a roster filled by a settled team is far easier to evidence than one assembled shift by shift.

The bottom line

For providers with clean rostering data and stable nursing rosters, this is an administrative exercise with a firm date on it. For providers who have been meeting the target by a narrow margin, or filling RN lines through a mix of agency and overtime, the audit will describe the workforce position more plainly than any internal report has. Either way the work belongs in August and September rather than October.