National Safety and Quality Health Service Standards: third edition - Submission to the Australian Commission on Safety and Quality in Healthcare
October 2025
PWDA welcomed the opportunity to provide a submission to the Australian Commission on Safety and Quality in Healthcare's consultation on the National Safety and Quality Health Service (NSQHS) Standards (third edition).
This submission and its recommendations have been underpinned by survey research that PWDA conducted with people with disability. Respondents shared their lived experiences of skilled, kind, accessible, holistic healthcare where they felt listened to, respected, and their adjustment needs were met.
The overarching theme of this submission is that greater consideration, understanding and resourcing of disability healthcare is needed to achieve quality, safe standards.
The third edition of the NSQHS needs to ensure that health system resourcing, health staff training, health service access and health facility accessibility are inclusive, equitable and support the rights and needs of people with disability to enjoy quality healthcare on an equitable basis with others.
Incorporating the recommendations contained within this submission into the third edition of the NSQHS Standards will improve the accessibility, inclusion, equity and effectiveness of Australian healthcare.
Recommendations
The Australian Commission on Safety and Quality in Healthcare has asked for written feedback to address 7 questions. Therefore, our recommendations are organised into two parts:
- Part 1: Examines the research we conducted with people with disability to understand their concerns and recommendations.
- Part 2: Addresses each of the seven questions we were asked to address, informed by our research from Part 1
Part 1: Research with people with disability
Recommendation 1
Require all hospitals to enable patients or their carers to report, and if necessary, escalate, critical safety concerns.
Recommendation 2
Require all hospitals to appoint Disability Liaison Officers and empower them to plan for and authorize the adjustments people need.
Recommendation 3
Require all hospitals to gather patient feedback, outcomes, identify and act on issues to improve healthcare quality and safety for people with disability, and report on this annually.
Recommendation 4
Require all hospitals to appoint a co-design group that includes people with lived experience of different disabilities, to examine all aspects of patient care and recommend reforms.
Recommendation 5
Require all health staff to undergo disability awareness training appropriate to their roles, facilitated by a person with lived experience of disability
Recommendation 6
Require all hospitals to provide accessible communication formats for all patients.
Recommendation 7
In addition to requiring all General Practitioners to complete training recommended above, fund the development of a Continuing Professional Development (CPD) resource library and work with Disability Representative Organisations and people with disability to develop training resources on different health and accessibility topics.
Recommendation 8
Undertake mapping of places where healthcare is inaccessible or absent, require annual reporting against how these inequities are being addressed.
Recommendation 9
Work with health professionals and their associations to expand access to bulk billing, especially in rural, regional and lower income areas.
Recommendation 10
In addition to expanding bulk billing, similar to general practice, require the publication of waitlists and gap fees wherever these exist.
Recommendation 11
Require mental healthcare facilities to form an advisory board of people with lived experience of different disabilities and service use, to examine all aspects of patient care and recommend reforms.
Recommendation 12
Require mental health professionals to undertake the training at recommendation 5, and also training related to intersectional and disability specific issues with mental healthcare.
Part 2: Submission questions
Recommendation 13
Require that a capacity audit be undertaken, and map created of under-served areas in terms of general practice, specialist care and hospital services
Recommendation 14
Require annual reporting of the actions taken to improve health services in areas identified under the capacity audit.
Recommendation 15
Co-design disability awareness training for health professionals with disability and require rollout, the implementation of performance measures and reporting.
Recommendation 16
Develop and implement communication tools and processes that promote service integration.
Recommendation 17
Co-design care with patients and create accountability for prompt and effective care.
