Care Minutes Performance Statement Audit: What Aged Care Providers Must Prepare for 2025-26

Compliance

April 14, 2026

Why regulated care providers must move beyond audit cycles and build real-time compliance systems.

From 1 July 2025, every residential aged care provider in Australia became responsible for meeting legislated care minute requirements. Now, with the 2025-26 financial reporting period well underway, providers face another critical milestone: the submission of an audited Care Minutes Performance Statement alongside their Aged Care Financial Report. In March 2026, the Department of Health released updated auditor guidance to support this process. This guide breaks down what the audit involves, what documentation you need, and how to prepare your records for a smooth audit experience.

What Is the Care Minutes Performance Statement?

The Care Minutes Performance Statement is a mandatory financial reporting requirement introduced under the Aged Care Act reforms. It requires residential aged care providers to report on their total care minutes delivered, broken down by registered nurses, enrolled nurses, and personal care workers. The statement captures direct care time, on-floor presence, and how these compare against the legislated targets for your facility.

The requirement applies to all residential aged care services receiving Australian Government subsidies. Providers must report their performance for the full financial year, demonstrating compliance with the minimum care minute standards that came into effect on 1 July 2025. Understanding the fundamentals of care minutes compliance is essential before diving into the audit requirements.

The New Auditor Guidance: What Changed in March 2026

The Department of Health and Aged Care released updated auditor resources in March 2026 specifically for the Care Minutes Performance Statement. These guidelines clarify what auditors must assess when reviewing your submission. Key focus areas include:

  • Accuracy of care minute calculations and data sources
  • Consistency between reported figures and actual rostering records
  • Documentation of any exemptions or exceptional circumstances claimed
  • Verification that the statement reflects the full financial year
  • Appropriate governance and sign-off processes

Auditors are expected to apply professional scepticism and obtain sufficient appropriate evidence to support the figures in your statement. This means your documentation needs to be comprehensive, traceable, and readily accessible.

Documentation You Need to Prepare

Preparing for a Care Minutes Performance Statement audit requires pulling together records from across your organisation. The specific documents auditors will typically request include:

  • Monthly rosters and actual hours worked by care staff category
  • Payroll records that align with care minute calculations
  • Timesheets and attendance records for all nursing and care staff
  • Documentation of any agency or casual staff utilised
  • Evidence supporting any claimed exemptions
  • Board or management sign-off on the final statement

If your organisation has been relying on manual processes or spreadsheets to track these metrics, now is the time to consider whether your current system can efficiently produce this documentation. Many providers are finding that integrated governance and compliance systems significantly reduce the burden of audit preparation.

Common Pitfalls Providers Should Avoid

Early feedback from the Department and auditors has revealed several common issues that are tripping up providers:

  • Misaligned data sources: When rostering systems don't talk to payroll, discrepancies emerge that auditors will flag
  • Inconsistent categorisation: Staff roles must be correctly classified (RN vs EN vs PCW) for accurate reporting
  • Missing documentation: Claims without supporting evidence are likely to be challenged
  • Timing discrepancies: Ensure your reporting period aligns exactly with the financial year
  • Governance gaps: The statement must be properly reviewed and approved by leadership before submission

Providers who have already undergone ACQS 2025 assessments may recognise some of these challenges. The preparation principles for ACQS 2025 audits apply equally here: thorough documentation, clear accountability, and proactive governance.

How Automation Can Streamline Your Audit Readiness

The Care Minutes Performance Statement audit requirement adds to an already substantial compliance workload for aged care providers. Manual tracking and compilation of care minute data is not only time-consuming but increases the risk of human error that auditors will identify.

Modern compliance platforms can automate the collection and categorisation of care minute data directly from your rostering and payroll systems. Real-time dashboards let you monitor performance against targets throughout the year, rather than scrambling to compile figures at financial year-end. Automated alerts can flag potential compliance issues before they become audit findings.

More importantly, a well-designed system maintains a complete audit trail from source data through to final reporting. When auditors request evidence, you can produce it quickly and confidently. This doesn't just make audits easier—it demonstrates to regulators that your organisation takes compliance seriously.

Key Deadlines and Next Steps

The 2025-26 Aged Care Financial Report, including your audited Care Minutes Performance Statement, must be submitted in accordance with the Department's published timeline. Providers should be engaging with their auditors now to ensure adequate time for the audit process. Late or incomplete submissions carry regulatory risk and may attract scrutiny from the Aged Care Quality and Safety Commission.

If you haven't already:

  • Review the March 2026 auditor guidance in detail
  • Conduct an internal review of your care minute records for accuracy
  • Engage your external auditor early to discuss requirements
  • Ensure your board or management has sight of the draft statement before sign-off

Meeting care minute requirements is about more than compliance—it's about delivering quality care to residents. The audit process is an opportunity to validate that your organisation is fulfilling that commitment while maintaining the standards the community expects.

Written by

James Driscoll

Writer

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