Elder abuse in the federal context
1.76 Issues surrounding elder abuse relate to areas of Commonwealth, state and territory and possibly local government responsibility. For example, the Commonwealth makes laws relating to financial institutions, social security, superannuation and aged care. Laws relating to substitute decision making, including guardianship and powers of attorney, and most criminal laws, are the province of the states and territories. In the 2007 report, Older People and the Law, the House of Representatives Standing Committee on Legal and Constitutional Affairs described the legal landscape in this way:
Among the nine legal jurisdictions within Australia there are a number of laws that have particular relevance to older Australians. At the Commonwealth level, legislation in the areas of aged care, superannuation, social security and veteran’s entitlements is of particular relevance as we age. In state and territory jurisdictions, legislation relating to substitute decision making, guardianship, retirement villages, wills and probate affects the population as it ages. Criminal matters, such as fraud and other forms of financial abuse, are dealt with primarily at the state and territory level, although Commonwealth legislation covers certain criminal matters. Unlike a number of overseas jurisdictions, there are no specific laws in Australia dealing with what might be broadly classed as ‘elder abuse’.
1.77 This makes responding to elder abuse a complex issue—both from the perspective of laws, but also in terms of practical responsibility. Kaspiew, Carson and Rhoades commented that
responses to the management and prevention of elder abuse sit within a range of complex policy and practice structures across different levels of government, and various justice system frameworks within the private sector and across non-government organisations.
1.78 On the one hand, as Professor Wendy Lacey points out, the ‘responsibility for safeguarding vulnerable adults lies primarily with the state and territory governments’, but, on the other, ‘responsibility for ageing and aged care has increasingly been appropriated by the Commonwealth’.
1.79 In the ALRC’s 2010 Family Violence inquiry, the ALRC considered the complex interactions across the federal landscape, particularly between the Family Law Act 1976 (Cth) and state and territory family violence and child protection laws. In that context the ALRC identified, as a key policy goal, the aspiration of ‘seamlessness’. Where legislation includes different definitions and requirements, consistency has been identified as an important goal. As it was in the Family Violence Inquiry, a need for consistent laws was a dominant theme among stakeholders in this Inquiry. As National Seniors observed:
It makes little sense that the legal frameworks to protect older Australians from abuse differ across the various states and territories. National laws or at the least nationally consistent laws are required to reduce confusion and improve protections for older people.
1.80 National consistency of laws, such as state and territory powers of attorney and guardianship and administration laws is one goal, among many, that could be led through the National Plan process. A number of the proposals also express the idea of consistency that seamlessness embodies.
1.81 The idea of seamlessness is also seen in an emphasis on effective interventions to protect older persons from, or to respond to, abuse. This presents particular issues for this Inquiry in the federal context. As Kaspiew, Carson and Rhoades observed, ‘Commonwealth, state and territory governments have intersecting responsibilities in relation to ageing, aged care and health’. The Proposals in this Discussion Paper recognise the jurisdictional responsibilities of the different levels of government within a federal system and the need for integrated pathways to achieve a seamlessness of response. The Proposals also recognise where there are gaps in the current complaints and investigatory frameworks and where monitoring and supervision may be improved.
Elder abuse and family violence
1.82 Elder abuse is often committed by a family member of the older person—notably, by adult children, but also the older person’s spouse or partner. The essence of elder abuse in the WHO definition is the harm or distress caused by the person in a position of trust. Family violence exhibits similar dynamics. For example, it is defined in the Family Law Act 1975 (Cth) as meaning ‘violent, threatening or other behaviour by a person that coerces or controls a member of the person’s family or causes the family member to be fearful’.
1.83 The approach reflected in the WHO definition is wider than the concept of ‘family violence’, in that the relationships of trust may be wider than ‘family’ and the group of relationships listed in the Terms of Reference. However, elder abuse is closely related to family violence and, as Chesterman observed, ‘elder abuse is often also an instance of family violence’. Like family violence, elder abuse can be physical, sexual, psychological or financial in nature, and is usually committed by a family member; and available research also suggests that women are more likely to experience elder abuse than men. Some instances of elder abuse may be a continuation of family violence that began when the perpetrator and victim were not old. In other cases, ageism, cognitive impairment, social isolation or relationships of dependence may contribute to the risk of elder abuse.
1.84 The Office of the Public Guardian (Qld) said that
elder abuse manifests differently to the usual conceptions of domestic and family violence, particularly in terms of the perpetrator and type of abuse. For example, adult children are more likely to be perpetrators of abuse against an elderly parent, than the parent’s partner. The type of abuse is also more likely to be financial abuse, including misappropriation of finances and property; emotional abuse, including intimidation and controlling behaviour; or neglect, including under-medicating, over-medicating or not taking someone to the bathroom.
1.85 There may be some differences in the dynamics of family violence and elder abuse. Family violence is often characterised as a manifestation of power and control. There is less agreement about the dynamics of elder abuse. In 1999, it was said that ‘research to date has not been successful in identifying theoretical frameworks that are useful in understanding the issue as a social phenomenon’ and this may still be true today.
1.86 Professors Thomas Goergen and Marie Beaulieu note that a power imbalance may not be a necessary feature of elder abuse:
While the very act of abuse can often be regarded as exerting (and misusing) power, there is little reason to assume that abuse can only happen in relationships where the overall distribution of power and inﬂuence is in favor of the perpetrator. In family caregiving, structural aspects of the pre-caregiving relationship between spouses can remain relatively stable. The caregiving role may provide the caregiver with opportunities and situational triggers for abuse, but being in a position where one may be affected by abuse does not necessarily mean having less power and inﬂuence than the potential abuser. Acts of abuse and neglect may happen between persons where the overall distribution of power is equal or even in favor of the victim. However, differential power balance may still be regarded as a favorable constellation for abuse and neglect.
1.87 A particular manifestation of elder abuse is financial abuse. This may include pressure to sign a range of documents—including, for example, an enduring power of attorney and a will. While such pressure may include the element of control essential to family violence, there are additional aspects that characterise elder abuse. Seniors’ Legal and Support Service of the Caxton Legal Centre said that it was their experience that ‘a range of forms of abuse may be perpetrated on an older person with the primary aim of predation—in order to access their funds and/or property’.
1.88 The predatory nature of financial abuse forms part of what Protecting Seniors Wealth described as ‘the rapidly increasing wealth abuse epidemic called “Inheritance Impatience”’, driven, as another put it, by the fact that the older person ‘doesn’t die soon enough for the abuser’. Examples may be seen in relation to transactions that affect property during the lifetime of the older person—as for example through family agreements and the exercise of powers of attorney. The Australian Association of Gerontology suggested that these kinds of financial abuse reflect that
Family members may also regard older relatives’ assets as belonging to the family rather than the older relatives, since the assets will be coming to them as an inheritance in due course (or so they expect).
Elder abuse as a human rights issue
1.89 Kaspiew, Carson and Rhoades describe elder abuse as ‘fundamentally a human rights issue’. In its 2016 report, Elder Abuse in New South Wales, the New South Wales Legislative Council set out as its first recommendation that the approach to elder abuse should include ‘a rights based framework that empowers older people and upholds their autonomy, dignity and right to self-determination’.
1.90 Professor Wendy Lacey urged that human rights should be the ‘normative framework’ for adult protection. Many stakeholders similarly emphasised that elder abuse should be seen as a matter of human rights. The Law Council of Australia, for example, said that ‘it is vital that all legal responses are based on a rights based approach in which the will and preference of the older person is given primacy’.
1.91 Existing human rights instruments, including the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights, protect the rights of older persons equally with other persons. The Universal Declaration of Human Rights specifically protectsthe right to security in old age. Some instruments, such as the Convention on the Rights of Persons with Disabilities (CRPD) may be particularly relevant to older persons, given that the rates of disability increase with age.
1.92 There is no Convention specifically relating to the rights of older persons. However, the Open Ended Working Group on Ageing is currently considering whether there should be new human rights instruments relating to older persons. A number of non-binding international instruments, including the United Nations Principles for Older Persons and the Madrid International Plan of Action on Ageing,relate to the human rights of older persons.
1.93 The Office of the Public Advocate (Vic) emphasised that best practice legal responses to elder abuse are those which ensure that their adult protection laws and practices are consistent with human rights obligations, especially the CRPD. Moreover, a lack of appropriate action, as Leading Age Service Australia submitted, ‘detracts from a person’s rights and impacts on their dignity’. The Australian Association of Social Workers said that seeing elder abuse as a human rights issue requires ‘a comprehensive set of strategies, and the cooperation of multiple individuals and groups’:
Preventative strategies informed by human rights principles need to be the foundation of the response to elder abuse in the private and the public lives of older people, whether it be in the spheres of health, finance, education, care and support services, or recreation.
1.94 People with Disability Australia (PWDA) drew attention to the range of human rights instruments that may be relevant to the rights of older people, particularly older people with disability. It noted that, while the Convention on the Rights of Persons with Disabilities is the principal instrument, ‘it is not the only document relating to people with disability, or to older people’:
An intersectional response requires consideration of all human rights instruments to which Australia is a party, as well as those to which we are not. Particularly relevant in discussions of elder violence are the UN Principles for Older Persons, for instance. This document could be used to guide the ways in which elder violence is prevented, identified and addressed, ensuring that the rights of older people are at the forefront of any approaches.
1.95 The Older Persons Legal Services Network suggested that a rights-based approach should be underpinned by the understanding that there is no ‘normal older person’: ‘old age is a social and societal construct which continues to shift and evolve’.
1.96 Developing responses to elder abuse through a rights-based lens is not entirely straightforward, however. As Lacey points out,
The challenge for lawyers, advocates and policymakers is that the human rights of older persons have not yet been well defined in international human rights law, and governments (national, regional and local) are presently developing law and policy in the absence of a specific treaty with binding obligations to respect and protect the rights of older people. … [t]he only instruments specifically concerned with older persons reflect non-binding, soft law. … While the UN Principles [for Older Persons] are implicitly human rights-based, they are also written in aspirational terms and speak to others (that is carers and policymakers) rather than older persons. Further, the UN Principles do not speak of ‘rights’ at all, although they are framed around five core themes reflective of a human rights-based approach: independence, participation, care, self-fulfilment and dignity.
1.97 The rights-based framework is evident in the Terms of Reference. In giving the ALRC this Inquiry, the Attorney-General had regard to three matters:
that all Australians have rights, which do not diminish with age, to live dignified, self-determined lives, free from exploitation, violence and abuse;
that laws and legal frameworks should provide appropriate protections and safeguards for older Australians, while minimising interference with the rights and preferences of the person; and
relevant international obligations relating to the rights of older people under United Nations human rights conventions.
1.98 The objective expressed in the Terms of Reference is to identify best practice laws and legal frameworks that: promote and support older people to participate equally in their community and access services and advice; protect against misuse or advantage taken of formal and informal supporter or representative roles; and to provide specific protections. To meet this objective, and to express a rights-based framework, the ALRC considers that the proposals contained in this Discussion Paper should meet the following framing principles: dignity and autonomy; and protection and safeguarding.
Dignity and autonomy
1.99 The right to enjoy a dignified, self-determined life is an expression of autonomy. The UN Principles for Older Persons state this principle as requiring that:
Older persons should be able to live in dignity and security and be free of exploitation and physical or mental abuse.
Older persons should be treated fairly regardless of age, gender, racial or ethnic background, disability or other status and be valued independently of their economic contribution.
1.100 Dignity is a key principle in a number of international human rights instruments. In Australia, the National Disability Strategy prioritised the concept of dignity in its principles. Similarly, the Productivity Commission identified human dignity as ‘an inherent right’ of persons with disability and suggested that dignity as a human being is linked to self-determination, decision-making and choice.
1.101 The UN Principles for Older Persons also expressly include dignity as a principle in the context of older persons ‘in any shelter, care or treatment facility’, combined with the right to be self-determining: ‘full respect for their dignity, beliefs, needs and privacy and for the right to make decisions about their care and the quality of their lives’.
1.102 Dignity is a principle which acknowledges diversity. Thepreamble to the UN Principles for Older Persons acknowledges an appreciation of ‘the tremendous diversity in the situation of older persons, not only between countries but within countries and between individuals, which requires a variety of policy responses’.
1.103 Autonomy is a significant aspect of a number of the United Nations Principles for Older Persons that underlie the ability of persons to make decisions and choices in their lives: particularly the principles of ‘independence’, ‘participation’ and ‘self-fulfilment’. For example, the principle of self-fulfilment includes that ‘[o]lder persons should be able to pursue opportunities for the full development of their potential’. Autonomy is also enshrined in the general principles of the United Nations Convention on the Rights of Persons with Disabilities (CRPD), to which Australia was one of the original signatories. It is a key principle of the National Disability Strategy; and is reflected in the objects and principles of the National Disability Insurance Scheme. The ALRC Equality, Capacity and Disability Inquiry was informed by autonomy in the sense of ‘empowerment’, not just ‘non-interference’, which involves seeing an individual in relation to others, in a ‘relational’ or ‘social’ sense, an understanding that connects with respect for the family as the ‘natural and fundamental group unit of society’ that is entitled to protection by States Parties.
1.104 Dignity in the sense of the right to enjoy a self-determined life is particularly important in consideration of older persons with impaired or declining cognitive abilities. The importance of a person’s right to make decisions that affect their lives was a fundamental framing idea throughout the ALRC’s Equality, Capacity and Disability Inquiry. It reflects the paradigm shift towards supported decision making embodied in the UN Convention on the Rights of Persons with Disabilities and its emphasis on the autonomy and independence of persons with disabilities, so that it is the will and preferences of the person that drives decisions they make or that others make on their behalf, rather than an objective notion of ‘best interests’.
Protection and safeguarding
1.105 This Inquiry requires a particular focus on safeguards and protections for the rights of older persons, reflected in the title of the Terms of Reference: ‘Protecting the Rights of Older Australians from Abuse’. It is also the clear objective of the Inquiry. Safeguarding against elder abuse requires addressing a range of points of intervention, including those related to risk, reporting, response and redress. It requires appropriate mechanisms of accountability across the federal system.
1.106 Balancing autonomy with providing appropriate protections and safeguards against abuse is a particular challenge in the context of an ageing population—although many protections are entirely compatible with protecting a person’s autonomy. The National Ageing Research Institute (NARI) stated that the approach based on empowerment, works for people in a position to advocate for themselves, but it ‘doesn’t work for people with cognitive difficulties or limited capacity’.
1.107 Concerns about determining appropriate safeguarding responses may be increased in the context of a move towards more self-directed care, where older people are being supported to stay in their own homes for as long as possible. The benefits of a consumer or self-directed model of aged care—including greater independence and more choice, flexibility and control over services and support—have been well articulated in reforms to the aged care and disability sectors. While allowing more room for autonomous choices, it may also expose older people to new risks. Policy choices need to recognise this risk exposure with the aim of future-proofing reforms. New processes of accountability and transparency will be required, as part of the community’s responsibility to ensure older people are protected from potential abuse.
1.108 The focus of the protections canvassed in the ALRC’s proposals, particularly in the area of aged care, is on the safety of the individual. Some of the proposals have a regulatory aspect. In 2011, the Productivity Commission recommended reforms to streamline the regulatory framework. However, there remains an important role for regulation: as the Productivity Commission noted, ‘regulation plays an essential role in how the Government manages the risks to the wellbeing of older Australians and the fiscal risks to taxpayers’. Targeted regulatory oversight will be a key element in ensuring the safety of older people as more older people are not residing in aged care facilities but having services delivered to their homes.
1.109 One aspect of safeguarding responses is accountability. This is particularly relevant in the context of those who are supporting older persons in their decision making, and especially those who are in the position of substitute decision makers. In the Equality, Capacity and Disability Report, the ALRC said that another component of accountability was the personal accountability and responsibility for decisions by persons with disability themselves, ‘recognising that active participation involves both responsibilities and risks’.
1.110 Respecting the choices that older persons make but also safeguarding them is a challenge that is not necessarily easy to answer; and protective responses may lead to overreach. A particular example given in relation to hospitals was a failure to give effect to advance care plans, ‘overriding the person’s instructions and wishes’, pointing to this as an ‘abuse of people’s right to determine their own care, including decisions about when to cease types of care’. It was noted that ‘this may be due to a breakdown in communication, or may also be due to attitudes that dismiss the rights of older people to self-determination’.
1.111 Another aspect of safeguarding is access to ways for resolving concerns about abuse, including access to forums and means of redress for situations of elder abuse. The Law Council suggested that ‘particular emphasis ought to be placed on investigation, protection, reinstatement and remedies’. NARI noted, however, that older people ‘will often seek or only accept a harm minimisation approach’, hence they may choose not to actively pursue their rights. The Consumer Credit Legal Service (WA) commented similarly that, ‘even where the elderly person recognises that they have been abused, they may be ashamed of their inability to prevent that abuse and their perceived inadequacies’.
The Commonwealth’s powers to make laws relating to aged care arise from its legislative power to make laws regulating corporations providing aged care, funding programs administered by states and territories, and its powers relating to age pensions, carer pensions and other welfare regimes: Wendy Lacey, ‘Neglectful to the Point of Cruelty? Elder Abuse and the Rights of Older Persons in Australia’ (2014) 36 Sydney Law Review 99, 102. The Commonwealth’s powers in relation to taxation, financial institutions, social security and superannuation arise from the banking, social welfare and powers respectively: Australian Constitution s 51(ii), (xiii), (xxiii), (xxiiiA). The Commonwealth does not have an enumerated power to legislate with regard to the welfare of adults generally.
House of Representatives Standing Committee on Legal and Constitutional Affairs, Parliament of Australia, Older People and the Law (2007) [1.7].
Kaspiew, Carson and Rhoades, above n 12, 1.
Lacey, above n 96, 101.
Australian Law Reform Commission, Family Violence—A National Legal Response, Report No 114 (2010).
See, eg, Seniors Rights Victoria, Submission 171; Seniors Rights Service, Submission 169; Queensland Law Society, Submission 159; National LGBTI Health Alliance, Submission 156; National Seniors Australia, Submission 154; Townsville Community Legal Service Inc, Submission 141.
National Seniors Australia, Submission 154.
Kaspiew, Carson and Rhoades, above n 12, .
Family Law Act 1975 (Cth) s 4AB(1). This provision was introduced in 2011.
Chesterman, above n 8, 117.
Kaspiew, Carson and Rhoades, above n 12, 5.
Ibid ch 3.
Office of the Public Guardian (Qld), Submission 173.
Victoria, Royal Commission into Family Violence, Summary and Recommendations (2016) 18.
Pamela Kinnear and Adam Graycar, ‘Abuse of Older People: Crime or Family Dynamics’ (Trends & Issues in Criminal Justice 113, Australian Institute of Criminology, 1999) 6; Kaspiew, Carson and Rhoades, above n 12, ch 3.
Thomas Goergen and Marie Beaulieu, ‘Critical Concepts in Elder Abuse Research’ (2013) 25(08) International Psychogeriatrics 1217, 1225.
See, eg, Alzheimer’s Australia, Submission 80.
Protecting Seniors Wealth, Submission 111.
Name Withheld, Submission 133.
See Chapters 5 and 8.
Australian Association of Gerontology, ‘Submission to Legislative Council Inquiry into Elder Abuse in New South Wales’, November 2015, 7. See also Older Women’s Network NSW, Submission 136.
Kaspiew, Carson and Rhoades, above n 12, 1.
Legislative Council General Purpose Standing Committee No 2, Parliament of New South Wales, Elder Abuse in New South Wales (2016) rec 1.
Lacey, above n 96, 113.
Law Council of Australia, Submission 61.
International Covenant on Civil and Political Rights, opened for signature 16 December 1966, 999 UNTS 171 (entered into force 23 March 1976) art 2(1), 26; International Covenant on Economic, Social and Cultural Rights, opened for signature 16 December 1966, 993 UNTS 3 (entered into force 3 January 1976) art 2(2), 3; Office of the High Commission for Human Rights, Normative Standards in International Human Rights Law in Relation to Older Persons: Analytical Outcome Paper (August 2012) 8, 11–12.
Universal Declaration of Human Rights, GA Res 217A (III), UN GAOR, 3rd Sess, 183rd Plen Mtg, UN Doc A/810 (10 December 1948) art 25(1).
The CRPD states that ‘State Parties undertake to adopt measures to combat stereotypes, prejudices and harmful practices relating to persons with disabilities, including those based on sex and age, in all areas of life’: Convention on the Rights of Persons with Disabilities, opened for signature 30 March 2007, 999 UNTS 3 (entered into force 3 May 2008). Other conventions that may apply include: Convention on the Elimination of All Forms of Discrimination Against Women, opened for signature 18 December 1980, 1249 UNTS (entered into force 3 September 1981); Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, opened for signature 10 December 1984, 1465 UNTS 85 (entered into force 26 June 1987). For a discussion of age and disability, see Australian Institute of Health and Welfare, Australia’s Welfare 2011, Cat No AUS 412 (2011) 11–12.
United Nations General Assembly Open-Ended Working Group on Ageing, Report of the Open-Ended Working Group on Ageing, UN Doc A/AC.278/2015/2 (29 July 2015) 7.
United Nations Principles for Older Persons, GA Res 46/91, UN GAOR, 46th Session, 74th Plen Mtg, Agenda Item 94(a), UN Doc A/RES/46/91 (16 December 1991) annex 1.
Second World Assembly on Ageing, Political Declaration and Madrid International Plan of Action on Ageing, Madrid, Spain (8–12 April 2002).
Office of the Public Advocate (Vic), Submission 95.
Leading Age Services Australia, Submission 104.
Australian Association of Social Workers, Submission 153. The AASW noted that social workers are ‘integral to services that cater for the health and wellbeing of older Australians in all settings across the aged care continuum’.
People with Disability Australia, Submission 167.
National Older Persons Legal Services Network, Submission 180.
Lacey, above n 96, 114–115.
United Nations Principles for Older Persons, GA Res 46/91, UN GAOR, 46th Session, 74th Plen Mtg, Agenda Item 94(a), UN Doc A/RES/46/91 (16 December 1991) –.
See Universal Declaration of Human Rights, GA Res 217A (III), UN GAOR, 3rd Sess, 183rd Plen Mtg, UN Doc A/810 (10 December 1948) art 25(1); International Covenant on Civil and Political Rights, opened for signature 16 December 1966, 999 UNTS 171 (entered into force 23 March 1976); Convention on the Rights of Persons with Disabilities, opened for signature 30 March 2007, 999 UNTS 3 (entered into force 3 May 2008); International Covenant on Economic, Social and Cultural Rights, opened for signature 16 December 1966, 993 UNTS 3 (entered into force 3 January 1976).
Australian Government, National Disability Strategy 2010–2020, 22.
Productivity Commission, Review of the Disability Discrimination Act 1992 (Cth) (Report No 30, 2004) 182.
United Nations Principles for Older Persons, GA Res 46/91, UN GAOR, 46th Session, 74th Plen Mtg, Agenda Item 94(a), UN Doc A/RES/46/91 (16 December 1991) .
United Nations Principles for Older Persons, GA Res 46/91, UN GAOR, 46th Session, 74th Plen Mtg, Agenda Item 94(a), UN Doc A/RES/46/91 (16 December 1991).
Convention on the Rights of Persons with Disabilities, opened for signature 30 March 2007, 999 UNTS 3 (entered into force 3 May 2008).
Australian Government, National Disability Strategy 2010–2020, 22.
National Disability Insurance Scheme Act 2013 (Cth) ss 3–4.
Mary Donnelly, Healthcare Decision-Making and the Law—Autonomy, Capacity and the Limits of Liberalism (Cambridge University Press, 2010) 269–272. See her discussion particularly in ch 1, ‘Autonomy: Variations on a Principle’, in which she draws on the work of Joseph Raz: eg Joseph Raz, The Morality of Freedom (Clarendon Press, 1986).
John Christman, ‘Relational Autonomy, Liberal Individualism, and the Social Constitution of Selves’ (2004) 117 Philosophical Studies 143, 143.
International Covenant on Civil and Political Rights, opened for signature 16 December 1966, 999 UNTS 171 (entered into force 23 March 1976); Standard Rules on the Equalization of Opportunities for Persons with Disabilities, GA Res 48, UN GAOR, 3rd Comm, 48th Sess, Agenda Item 109, UN Doc A/RES/48/96 (20 December 1993) rule 9.
National Ageing Research Institute and Australian Association of Gerontology, Submission 65.
Department of Health (Cth), What Has Been Achieved so Far <agedcare.health.gov.au>.
See, eg, Productivity Commission, Caring for Older Australians (Report No 53, 2011).
Productivity Commission, Caring for Older Australians (Report No 53) 46.
Australian Law Reform Commission, Equality, Capacity and Disability in Commonwealth Laws, Report No 124 (2014) [1.39].
Quality Aged Care Action Group Incorporated, Submission 28. See also Social Work Department Gold Coast Hospital and Health Service, Queensland Health, Submission 30.
Law Council of Australia, Submission 61.
National Ageing Research Institute and Australian Association of Gerontology, Submission 65.
Consumer Credit Legal Service (WA), Submission 112.