This submission is a response to the Australian Department of Health's 2021 consultation paper, A New Residential Aged Care Accommodation Framework. The response advocates for an accommodation framework that:

• Is principle-based to encourage innovation, not a prescriptive approach that encourages ‘cookie cutter’ design. The framework should encourage innovation, consumer choice and control, and facilitate a variety of accommodation models responsive to consumer preferences.
• Is evidence based, which also actively enables innovation, and we provide a detailed but not comprehensive list of research literature.
• Recognises that even the best accommodation design alone does not produce good outcomes. They are a function of the whole approach – culture, workforce structure and support, training, models of care, clinical expertise, leadership, governance are all critical. The Accommodation Framework is interdependent with other aspects of reform, and it must say so and point to them, and not imply that good design produces results on its own. Institutional, non-relational and controlling approaches to care can operate in large and small, new and old built forms, even in in-home care.
• Does not consider the capital costs of different built forms from a short-term purely financial perspective but must be balanced with benefits to residents and to the long run interests of provider, taxpayer and community.
• Recognises the evidence of how design impacts on the prospect of better infection control, as demonstrated during the current pandemic, and on the implications for residents and staffing of different built forms when there is an outbreak.
• Does not add to complexity, duplication and inflexibility but encourages innovative approaches, within the proper requirements of building codes and accessibility guidelines.