The roster says one thing. The timesheet says another. Payroll has a third figure, and the agency invoices arrive at month end as PDFs that nobody parses. Each system is right about its own contents. Put them side by side and they disagree, and somebody in finance closes the gap by hand every quarter.
That has been survivable. On 31 October 2026 it stops being survivable.
Starting with the 2025-26 Aged Care Financial Report, the Department of Health, Disability and Ageing requires every residential aged care provider to prepare a Care Minutes Performance Statement and to engage a registered company auditor to audit it. The statement covers direct care minutes delivered, the associated labour hours and costs, registered nurse coverage and occupied bed days. The department’s guidance for auditors, published February 2026, sets the assurance level at reasonable assurance, the highest obtainable. For the first year the statement covers registered nurse coverage from 1 November 2025, when the Aged Care Act 2024 commenced, and care minutes performance from 1 January 2026, being quarters three and four. There is no extension; the department’s ACFR guidance states that neither the Act nor the Aged Care Rules 2025 provides for a later reporting date, and that none will be granted. Failing to comply with the audit requirement breaches section 166-335 of the Rules and may attract a civil penalty.
What the auditor does with it is set out in the guidance. They trace reported care time back through the provider’s systems, vouch it to signed timesheets or electronic verification logs, reconcile paid hours against reported hours in payroll, and perform cut-off testing. Rosters, timesheets, payroll, agency invoices. Four systems. One number?
The part that gets missed is this. You have already reported that number. Care minutes go to the department every quarter through the Quarterly Financial Report, and since 1 April 2026 the care minutes supplement has been paid against that quarterly data on a two-quarter lag, so the October to December 2025 quarter set the rate for April, May and June 2026. The guidance says it plainly in its section on materiality: quarterly payments are based on performance reported in the QFR, and the department then reconciles that against the Performance Statement annually so that payments reflect actual performance. So the exposure is not a number you are about to produce. It is the distance between a number you already sent and a number an auditor will now derive from your rosters.
Getting four systems to agree before the auditor turns up is a data engagement.
I used to file this kind of work under compliance, which meant filing it under someone else’s job. That was wrong, and the thing that corrected me was watching a reconciliation fail for reasons that had nothing to do with care and everything to do with definitions. A care worker’s time classified one way in the rostering system and another way in payroll. A shift split across midnight counted twice in one place and once in the other. An agency invoice covering three staff across two homes, arriving as a single line item. None of that is a care problem. All of it lands in the Performance Statement.
The guidance names the failures it expects, and they are not care failures. Where a service has attributed personal care worker time to direct care too generously, it says the opinion may be qualified. Where a provider has multiple instances of not keeping proper records of staff duties, a disclaimer of opinion. Where duty statements conflict with what staff say in interview, an adverse one. It also works the problem as a case study: a provider whose system reports on fortnightly payroll cycles while the statement reports monthly and quarterly, and the auditor is directed to consider what that misalignment does to the numbers. That is a join, described by the regulator, in a document written for the person who will be testing yours.
None of this stays inside the audit. The report is addressed to both the provider and the Secretary, and the guidance requires the engagement to permit distribution to the department. The same data drives the Star Ratings staffing subcategory, which the guidance says is initially reported through the QFR and then validated against the assured statement.
The money is specific. Under the April 2026 changes, Base Care Tariff funding for non-specialised metropolitan homes dropped from 0.5 to 0.387 NWAU, with the remaining 0.113 redirected into the care minutes supplement, worth up to $33.41 per resident per day at the AN-ACC price of $295.64. The rate then runs on a sliding scale against both targets, and the scale collapses at the bottom: a home under 85 per cent on both its total and RN care minutes receives nothing at all, and one under 85 per cent on total minutes receives no more than $2.96 even with RN coverage at full compliance. Worth noting who this applies to, since it is widely reported as though it were universal. It covers non-specialised homes in MM1 areas only, which is a bit over 60 per cent of residential care homes. Homes in MM2 to MM7, and MM1 homes with specialised homeless funding status, are outside it. The audit obligation, however, applies to every provider.
That pressure is not hypothetical. FicusBridge’s Dr Tanvi Dalal, analysing the department’s home-level data for January to March 2026 and reported by Australian Ageing Agenda in July, found 931 of 2,559 homes missed their care minutes responsibility, 36 per cent, up from 33 per cent the quarter before. Metropolitan homes accounted for 562 of them. That is a performance figure rather than a data figure, and under audit the two are hard to separate. A provider who delivered the minutes and cannot evidence them ends up in the same room as a provider who did not deliver them.
The error runs the other way too, and that one gets talked about less. The same analysis puts sector over-delivery at roughly $95 million of care minutes in the quarter: time delivered above target, paid for by the provider, and unfunded, because the supplement stops at 100 per cent. Under-report and you lose money you earned. Over-deliver without seeing it and you spend money you will never recover. Both are the same failure underneath, which is not knowing what your own number is until the quarter has closed and the figure has already gone to the department.
The work that closes this is unglamorous, and it is not an accounting engagement. Agree the definitions once and write them down. Map each field to the system that owns it. Reconcile a single quarter end to end and find where the numbers part company. Fix the join, not the spreadsheet. Then run it again on the next quarter and see whether the fix held. Any provider can do this with their own people, and the ones who start now will do it calmly.
The auditor will not build it for you. The standard requires their independence from the thing they are testing, so what arrives on their desk is whatever the provider assembled.
Two months. If you are running the numbers by hand each quarter, you already know which join is broken. It is the one you fix last, in the dark, the night before the report is due.
If you would rather not do that alone, we do it together: one quarter reconciled end to end, the definitions written down so the next quarter repeats without heroics, and a list of every join that does not hold. Fixed fee, scoped once, priced on the number of homes and the number of systems holding the data. That is not the audit. It is the thing you hand the auditor.
Sources
Department of Health, Disability and Ageing, Audit requirements for Care Minutes Performance Statement: guidance for auditors, February 2026: health.gov.au/sites/default/files/2026-02/audit-requirements-for-care-minutes-performance-statement-guidance-for-auditors_0.pdf
Department of Health, Disability and Ageing, Care minutes funding changes, April 2026, fact sheet: health.gov.au/sites/default/files/2026-03/care-minutes-funding-changes-april-2026.pdf
Department of Health, Disability and Ageing, Aged Care Financial Report guidance and FAQs 2025-26: health.gov.au/resources/publications/2025-26-aged-care-financial-report-guidance-and-faqs
Department of Health, Disability and Ageing, Care Minutes Performance Statement: health.gov.au/our-work/care-minutes-registered-nurses-aged-care/care-minutes/care-minutes-performance-statement
Australian Ageing Agenda, Providers over-delivering $95m worth of care mins a quarter, 9 July 2026: australianageingagenda.com.au/executive/policy/providers-over-delivering-95m-worth-of-care-mins-a-quarter/