Aged care and disability services share a defining characteristic that sets them apart from most other industries: the people they serve are among the most vulnerable members of the community. Residents of aged care facilities, participants in the National Disability Insurance Scheme (NDIS), and clients of community-based disability services depend on their carers for assistance with the most fundamental aspects of daily life — personal care, medication administration, mobility, nutrition, and emotional support.

This vulnerability creates a heightened duty of care that has direct implications for how organisations in these sectors manage the risk of substance impairment among their workforce.

The Vulnerability of Clients

The clients of aged care and disability services are uniquely vulnerable for several reasons:

• Physical dependence — many clients rely entirely on carers for mobility, personal hygiene, and feeding. An impaired carer handling a person during a manual transfer creates a direct risk of injury — to the client and to themselves.
• Cognitive impairment — clients with dementia, intellectual disability, or acquired brain injury may be unable to recognise impaired behaviour in their carer or to report it to others.
• Communication barriers — some clients cannot communicate verbally, making it difficult or impossible for them to raise concerns about the quality or safety of the care they are receiving.
• Isolation — care is often provided in private settings — a client’s home, a shared residential room, or during transport. There may be no other person present to observe or intervene if the carer is impaired.
• Power imbalance — the carer-client relationship involves an inherent power imbalance. Clients may be reluctant to complain about their carer for fear of retaliation or loss of service.

These factors mean that the consequences of impaired care delivery can be severe and may go undetected for extended periods.

NDIS and Aged Care Quality Standards

NDIS Practice Standards

Providers registered with the NDIS Quality and Safeguards Commission must comply with the NDIS Practice Standards. These standards include requirements for:

• Human resource management — ensuring that workers are appropriately qualified, competent, and fit to deliver services.
• Risk management — identifying and managing risks to the safety of participants.
• Incident management — having systems to identify, report, and respond to incidents, including incidents that may involve impaired worker behaviour.

While the NDIS Practice Standards do not specifically mandate drug and alcohol testing, the underlying requirements for worker fitness, risk management, and participant safety provide a clear basis for implementing a testing program.

Aged Care Quality Standards

The Aged Care Quality Standards, administered by the Aged Care Quality and Safety Commission, similarly require providers to:

• Ensure that the workforce is sufficient, skilled, and competent to provide safe and quality care.
• Have a clinical governance framework that includes systems for managing risk.
• Manage incidents and complaints effectively.

Following the Royal Commission into Aged Care Quality and Safety, there has been increased scrutiny of workforce quality and safety in aged care. Drug and alcohol testing is one mechanism that supports compliance with these quality standards and demonstrates the provider’s commitment to protecting residents.

Workforce Challenges

The aged care and disability services sectors face significant workforce challenges that affect the implementation of drug testing programs:

Workforce Shortages

Both sectors experience chronic workforce shortages, particularly in regional and remote areas. Some organisations may be reluctant to implement testing for fear of losing workers who are already difficult to recruit and retain. While this concern is understandable, it cannot override the duty of care to clients. A worker who is impaired by drugs or alcohol is not providing safe care, regardless of how difficult they would be to replace.

Casual and Agency Workers

The aged care and disability sectors rely heavily on casual and agency workers to fill roster gaps. These workers may move between multiple employers, making consistent testing coverage more difficult. Your testing program should explicitly cover casual and agency workers, and you should verify with labour hire agencies what testing their workers have undergone.

Sole Workers

Many disability support workers and some aged care workers operate alone — providing in-home support, community access, or overnight supervision without a colleague present. This isolation means there is no co-worker to observe signs of impairment. Random testing provides a deterrent and detection mechanism that partially addresses this gap.

Balancing Safety and Privacy

As with healthcare, implementing drug testing in aged care and disability services requires a careful balance between the duty of care to clients and the privacy rights of workers.

The Case for Testing

• Clients are among the most vulnerable people in the community.
• Carers have unsupervised access to clients, often in private settings.
• Impaired care delivery can cause serious physical and psychological harm.
• Quality standards require providers to ensure workforce fitness and manage risk.

Privacy Safeguards

• Test results are health information and must be stored securely with restricted access.
• The testing program should be proportionate to the identified risks.
• Workers must be informed about the testing program and their rights.
• A confidential disclosure pathway should be available for prescription medications.
• Results should only be shared with those who have a legitimate need to know.

Implementing Testing Sensitively

The care sector attracts people who are motivated by a desire to help others. Introducing drug testing can be perceived as a statement of distrust if it is not handled carefully. Sensitive implementation is essential for workforce acceptance.

Communication and Framing

• Frame the program around client safety — most care workers will readily understand that protecting vulnerable clients is the primary purpose. Position the testing program as an extension of the duty of care that already guides their work.
• Emphasise fairness — explain that random testing means everyone has an equal chance of being selected, and that the program is not targeted at any individual or group.
• Highlight support — make it clear that the organisation provides genuine support for workers who may be struggling, including access to an Employee Assistance Program and rehabilitation pathways.

Practical Considerations

• Testing in the field — many care workers operate from clients’ homes rather than a central facility. Consider how random testing will be conducted for a dispersed workforce — options include testing at shift handover, at the office before or after community visits, or through scheduled collection events.
• Rostering impacts — removing a worker from a shift for testing has immediate implications for client care. Plan for replacement coverage when a worker is stood down pending a test or result.
• Cultural sensitivity — the aged care and disability workforce is culturally diverse. Testing procedures and communications should be available in relevant languages and delivered with cultural awareness.

Protecting Those Who Cannot Protect Themselves

Drug and alcohol testing in aged care and disability services is, at its core, about protecting the people who are least able to protect themselves. A well-designed, sensitively implemented program strengthens the safety framework that quality standards require and demonstrates the organisation’s genuine commitment to client welfare.

If your aged care or disability services organisation is ready to implement a testing program that meets your duty of care obligations, FairTest provides the tools to manage testing across dispersed care workforces — from automated selections and mobile test recording to secure record-keeping and compliance reporting. Start your free trial today.