Seven barriers that trip Aged Care providers in meeting the 215 minute rule
Diana Bevington, CEO, Bevington Partners
From 1 April 2026, metropolitan residential aged care providers that do not deliver an average of 215 minutes of direct care per resident per day, including 44 minutes from registered nurses (RNs), will face funding reductions at a time when many services are still working to understand how to meet these requirements consistently. These obligations sit on top of existing workforce, compliance and financial pressures, and they demand a level of operational clarity that many organisations have not yet needed to establish.
The question for leaders is no longer whether the targets are achievable in principle, but how quickly and reliably can each facility align its processes, workforce and reporting to deliver them.
For executive teams, the immediate priority differs depending on their current position. For providers already delivering the required care minutes, the task is to test how sustainable and resilient their current model is under full demand and operational pressure. For those not yet meeting the 215 minute target, the focus is on identifying where additional capacity can be found within existing resources, without driving unsustainable cost increases or compromising other aspects of service performance.
For both groups, the key question is how quickly they can make these adjustments, because decisions about methodology and implementation approach are now strategic choices that will shape the financial and clinical resilience of residential aged care services under the care minutes scheme.
Facilities that treat the requirement as a narrow staffing ratio problem will fail, while those that approach it as a whole of service operating model challenge have a clearer path to sustainable compliance.
A system-wide step-changed in expectations
Since 1 October 2024, registered providers of residential aged care have been required to deliver a sector-wide average of 215 minutes of direct care per resident per day, including 44 minutes provided by RNs. From 1 April 2026, metropolitan providers that fail to meet these targets face funding reductions of up to $33.41 per resident per day, equivalent to more than $1.15 million per annum for a 100-bed facility. Despite substantial funding uplifts, only 37.4 per cent of homes had met both targets as at December 2024, and around 1,000 homes remained non-compliant in late January 2026.
These figures highlight that the issue is not simply resourcing, but the way care delivery systems actually function day to day. The care minutes regime exposes hidden inefficiencies, fragmented processes and weak visibility across the care continuum that were previously manageable but are now commercially and clinically material.
The Operational Barriers to Delivering Care Minutes
The care minutes policy seeks to ensure that residents receive sufficient direct care. However, many providers are discovering that compliance requires more than incremental adjustments. Several systemic issues are limiting the sector’s ability to translate workforce hours into measurable direct care.
1. Hidden operational waste erodes care minutes
Residential aged care workers spend a significant share of their shifts on non-care activities such as
duplicated documentation
correcting errors in medication charts
chasing missing information
re-entering data across systems
completing incomplete handovers
addressing downstream consequences of earlier process failures
This activity, described in the XeP3 methodology as noise, absorbs time that could and should be counted as direct care minutes, but is instead lost to administrative inefficiency. As a result, facilities can have staff physically present on shift yet still fall short of the 215-minute target because too much of their time is consumed by non-value adding work.
For aged care providers, this means that the challenge is often not a lack of effort or commitment by staff. Instead, valuable clinical time is lost within poorly designed or fragmented processes.
XeP3 defines this noise through the five Cs: duplicated checking, correcting, completing, chasing and managing consequences of earlier process breakdowns. Research across 268 interventions found organisations carry a median noise level of 38 per cent, equating to nearly two days per week per employee spent on non-value adding tasks, with healthcare organisations specifically carrying a median noise level of 34.4 per cent. Conventional process mapping methods tend to miss this reality, with XeP3’s research finding that standard maps fail to capture two in every three activities performed, particularly the rework and workaround steps that generate most of the waste.
The XeP3 digital approach addresses this gap by asking every frontline staff member, including RNs, enrolled nurses and personal care workers, to document everything they actually do, including the informal practices and workarounds that never appear on traditional process charts. Using bottom-up data collection, XeP3 uncovers this hidden activity within the first two weeks, quantifies how many minutes per shift are lost to noise, and shows where providers are already paying for care minutes that are not being delivered. This evidence base enables leaders to see precisely where care time can be recovered without increasing headcount.
2. Workforce shortages limit hiring based solutions
Australia faces a projected shortage of more than 110,000 aged care workers within the coming decade, with annual turnover in residential care around 29 per cent and rising to 35 per cent among RN. Wages in aged-care remain below those in acute health, and more than 10,000 nurses and care staff left the sector in a single quarter during 2023. For many providers, the notion of recruiting their way to care minutes compliance is not realistic in the current labour market.
Under these conditions, compliance depends on creating additional capacity within the existing workforce rather than relying on increased staffing. If clinical and care staff in an aged care home carry even the healthcare median noise level of 34.4 per cent, more than one third of their paid time is currently non-productive. XeP3 supports providers to model the operational impact of removing specific sources of noise and to calculate exactly how many additional direct care minutes per resident per day can be liberated without hiring extra staff.
Evidence from a healthcare implementation at the Peter MacCallum Cancer Centre illustrates what is possible when noise is systematically addressed. There, the XeP3 digitised method removed 24 per cent of waste from doctors’ days and 42 per cent from administrators’ days, converting that time into direct patient facing activity. For residential aged care, even recovering 15 to 20 per cent of staff time from noise represents a material uplift in deliverable care minutes and can be the difference between meeting the target and incurring penalties.
3. Limited end to end visibility across care delivery
Care delivery in residential aged care involves numerous handover points throughout the day by multiple professional roles including:
RNs
enrolled nurses
personal care workers
lifestyle coordinators
administrative staff
support services such as kitchen and cleaning teams
Errors and inefficiencies upstream, such as incomplete clinical assessments, missing medication orders or poorly documented care plans, propagate downstream as rework and delay across multiple teams. Many providers lack a systematic way of seeing how waste in one area creates cascading problems across the entire care delivery chain. Without a clear view of the full care delivery process, operational improvement efforts tend to focus on isolated symptoms rather than underlying causes.
The XeP3 digitised methodology addresses this by using a Vertical Process Vertical model that maps detailed activities both functionally within each team or role and horizontally across end-to-end processes. This approach makes visible the waste that is caused in one department, for example incomplete pharmacy orders, but manifests in another, such as registered nurse time spent chasing corrections. The research underpinning XeP3 found that localised, spot-based lean improvements often address symptoms rather than root causes and are a primary reason why lean implementations fail to deliver lasting results.
By contrast, the whole of facility view enabled by the Vertical Process Vertical model allows aged care providers to understand how their care minutes are actually being consumed and where system level changes, rather than isolated fixes, are required. This end-to-end visibility is central to making informed decisions about where to focus limited improvement resources to maximise the impact on care minutes.
4. Rostering complexity and workforce planning
Delivering mandated care minutes requires careful alignment between several variables:
resident acuity levels under AN-ACC classifications
staff skill mix
shift rostering
leave and absenteeism
use of agency staff
Many providers continue to rely on rolling master rosters with limited integration between clinical, rostering and financial functions, designed around historical norms rather than mandated care intensity targets. Fluctuations in resident acuity, staff absenteeism and outbreaks further destabilise these static arrangements.
XeP3’s scenario modelling capability enables providers to model future state processes and calculate the precise resource implications of proposed changes before they are implemented. Within the XeP3 platform, the future state is modelled in detail, showing how changes will affect each role’s workload and time allocation. For aged care, this allows providers to model different rostering scenarios against their specific AN-ACC based care minutes targets, quantify the care minutes impact of removing particular noise drivers and assess the impact of reducing agency reliance by redeploying capacity freed through waste reduction.
As resident care needs change from quarter to quarter, the model can be updated, converting rostering from a reactive, static exercise into a data driven, forward looking planning discipline directly tied to compliance obligations. This improves the organisation’s ability to maintain compliance as circumstances shift, rather than continually reacting to shortfalls after they arise.
5. Temporary improvements and the challenge of sustainment
Residential aged care providers frequently attempt operational improvements such as:
revised documentation processes
new handover procedures
adjustments to rostering practices
However, these initiatives often revert to previous practices within a relatively short period.
High staff turnover accelerates this regression to old practices, and government impact analysis has highlighted the risk that providers will struggle to sustain improvements once regulatory pressure eases. In this context, temporary gains are not sufficient to support reliable care minutes performance.
This highlights the importance of embedding operational changes in a way that ensures they persist beyond initial implementation.
The XeP3 method incorporates Behavioural Change Indicators, or BCIs, as a mechanism to lock in new practices. BCIs are specific, measurable indicators directly linked to each deployed process change that confirm whether the new way of working is being followed at the task level. Unlike generic KPIs, they are tied to the actual activities of specific roles and teams and are agreed and accepted by individuals, managers and business units.
Peer reviewed research found that BCIs are central to making XeP3 improvements permanent, because they create clear accountability while avoiding reliance on top-down policing. The XeP3 platform provides a dashboard for capturing, measuring and reporting on BCIs, enabling managers to detect drift early and intervene before compliance is compromised. For care minutes specifically, BCIs can be used to track adherence to redesigned care delivery processes and to verify that time recovered from noise elimination is consistently redirected to direct care rather than absorbed by new forms of waste.
6. Staff engagement and resistance to change
The residential aged care workforce operates under significant pressure.
Common factors include:
heavy workloads
emotional demands of care
workforce shortages
administrative burdens
Top-down mandates to work differently or deliver more care minutes, without addressing the underlying sources of frustration, risk further attrition and undermine improvement efforts. Government analysis has acknowledged that the people component of change is often underemphasised in improvement programs.
The XeP3 methodology has been designed as a sociotechnical system that integrates human factors with technical process change. Research shows that when staff are asked to document their own activities, they tend to respond positively because it gives them permission to surface the issues they experience in their daily work. A typical staff response recorded in the research was that it felt as though the organisation was at last looking at the real problems in the department.
In the XeP3 approach, employees themselves develop most of the change proposals, so when implementation begins, they already understand why the change is needed, what it involves and who will benefit. The research found this approach effectively overcomes two of the most common barriers to lean success, namely lack of commitment from senior managers and resistance to change, because the data makes the scale of the opportunity evident to leaders and bottom-up solution design builds staff ownership. For residential aged care, this means RNs, enrolled nurses and personal care workers are not simply instructed to find more care minutes but are supported to identify and remove the noise that prevents them from providing the care they are trained to deliver.
7. Reporting burden and compliance assurance
From 2025-26, providers must prepare a Care Minutes Performance Statement, subject to external audit, in addition to existing Quarterly Financial Report obligations. Government impact analysis indicates that care time reporting assessments can require between 20 and 120 hours of administrative effort per home. This reporting workload competes directly with the time and attention needed to improve care-delivery and manage day-to-day operations.
XeP3 addresses this by providing quantified, auditable data on how staff time is allocated across value-adding and non-value adding activities. Every activity documented in the platform is time allocated and coded, creating a robust data trail that supports internal management reporting and external compliance assurance. Process analytics within the platform operate at three levels, offering staff reporting to show frontline workers where they can improve their daily work, management reporting to inform how teams can be structured more effectively and executive reporting to show how business processes align to strategic goals and operating expenditure.
This tiered reporting structure allows the same dataset used to drive operational improvement to support the evidence base for care minutes compliance reporting, reducing additional administrative burden rather than adding to it. For C suite leaders, this integration of improvement and assurance is central to managing both regulatory and financial risk in the care minutes environment.
Speed of implementation under time pressure
With the 1 April 2026 penalty date approaching, implementation speed is a critical factor. Traditional improvement programs often involve months of interviews, workshops and analysis before any change is enacted, a timeline that is misaligned with the current regulatory deadlines. XeP3’s digitalised approach is designed to deliver actionable insights within weeks, not months.
In practice, XeP3 implementations typically proceed on a six-week cadence. In weeks one and two, all staff document their detailed activities directly into the platform in parallel, removing the need for sequential interviews. In weeks three and four, XeP3 constructs the end-to-end process map, quantifies noise and identifies priority improvement areas. From week five onwards, implementation of process changes begins, with scenario modelling used to confirm the care minutes impact of each change.
Peer reviewed research[1] has confirmed that employee data capture is completed within two to three weeks even in large organisations and that analysis phases conclude within three weeks. For residential aged care providers facing imminent funding risk, this means measurable progress toward care minutes targets can commence within the current financial year, rather than being deferred to a future planning cycle.
Evidence base for the XeP3 methodology
The XeP3 platform is the commercial application of a digitalised lean management method developed over 25 years and validated across multiple industries. The methodology has been tested in 278 transformation projects across 17 industry sectors, including 30 healthcare implementations. Peer reviewed research published in the Australian Journal of Management in 2025 demonstrated that 100 per cent of projects that implemented XeP3 recommendations achieved measurable waste reduction, with healthcare organisations typically carrying a median noise level of 34.4 per cent.
Across 268 intervention-based research cases, 198 projects proceeded to implementation, and all of these recorded waste reduction outcomes. In a major Australian hospital, the method was used to eliminate a 29-day diagnostic delay and to deliver annual savings of $1 million. These findings indicate that XeP3 is not a theoretical framework being trialled in aged care, but a practical methodology with established healthcare credentials.
For C suite leaders, the significance of this evidence base is that it provides a credible foundation for decisions about resource allocation and change priorities. The methodology has demonstrated its capacity to uncover noise at scale, support staff engagement, quantify the impact of proposed changes and sustain improvements over time. In the context of care minutes compliance, these capabilities map directly to the sector’s most pressing operational challenges.
A practical pathway to sustainable compliance
The care minutes compliance challenge is not, at its core, a workforce numbers problem. It is an operational efficiency problem. The staff time required to meet the 215-minute target exists, in many cases is within the facilities. But it is being consumed by process waste that is invisible to standard management tools.
Resolving it requires an approach that can locate and quantify that waste precisely, model the operational impact of removing it, engage staff in building and owning the solution, and sustain the change through accountability mechanisms that outlast any single improvement initiative.
The April 2026 deadline does not allow time for multi-stage consulting engagements or iterative pilot programmes. Providers need a method that can begin generating actionable insight within days, deliver implementation-ready recommendations within weeks, and produce auditable compliance data from the outset.
That is what XeP3 was built to do, and what the evidence demonstrates it consistently delivers.
For many providers, the challenge now is not simply understanding the care minutes requirement. It is developing the operational capability needed to deliver it consistently and sustainably.
[1] Samson, D., Ho, W., Seyedghorban, Z., Bevington, D., & Kelly, S. (2026). Solving the paradox of Lean Management’s low success rate. Australian Journal of Management, 51(1), 264-290.