HELF: What Providers Need to Get Right With the Higher Everyday Living Fee

The headline message from the regulator in their most recent webinar on the Higher Everyday Living Fee (HELF) is simple: HELF must be genuinely additional, genuinely optional and genuinely valuable to the older person. A provider should be able to clearly demonstrate the difference between the services a resident is already entitled to receive as part of the standard service offering, and the additional service for which the resident is being charged a HELF.

The starting point most providers underestimate: the Residential Care Service List

Before any of the takeaways below, there is a threshold issue. The “standard service” is not whatever a provider has historically delivered or what its brochures describe. It is defined by the Residential Care Service List in the Aged Care Rules 2025, and a HELF can only be charged for services that are of a higher standard than those on the service list, or that are not on the list at all.

In our experience, many providers do not yet understand the intricacies of the service list: what it actually obliges them to deliver, at what standard, and where the boundaries genuinely sit. That gap is not a technicality. If you cannot say precisely what the service list requires of you, you cannot reliably say what is “additional”, and every downstream judgement about HELF, from pricing to bundles to consent conversations, is built on an uncertain foundation. It is also where complaints are most likely to land, because charging a HELF for something the service list already requires is exactly the practice the regulator has flagged.

The Department’s provider guidance on the service list and HELF is essential reading, but working through the list line by line against your own service offering is where the real clarity comes from.

1. Choice is fundamental

HELF cannot be a condition of entry, and it should not be agreed to or charged before admission as though it is simply part of entering the home.

The additional service should enhance the resident’s experience, and providers need to be able to demonstrate that residents have genuinely been able to choose whether they want it. Engagement with residents about what they value and want is therefore not a nice-to-have. It is the foundation of a defensible HELF arrangement.

2. Bundles will receive particular scrutiny

There was a strong caution around bundles.

Residents should not be required to purchase additional services only through a bundle. Providers should also be careful about an “insincere” bundle discount, for example where the bundle appears cheaper than purchasing each item separately but includes services the resident is unlikely to use.

The underlying test comes back to whether the offering is genuinely aligned to the resident’s needs and choices.

3. Food and nutrition is a particularly sensitive area

Complaints are already arising where providers appear to be charging additionally for food or nutrition that should form part of the standard service.

There needs to be a clear distinction between meeting the resident’s nutritional requirements and providing choice as part of the standard service, versus a genuinely additional food or dining experience that enhances the resident’s experience.

For us, this is an area where providers will need to exercise particular care in how they design and describe their HELF offering.

4. Evidence of the conversation matters

It is not enough to have an attractive HELF brochure or a signed form.

There was considerable emphasis on being able to demonstrate that the older person understood what was included, understood the price and value, had sufficient time to consider the offering, was not pressured, understood what they could actually receive and use, and where appropriate had family or others involved in helping them make the decision.

The expectation is for conversations to be open and respectful, with adequate time provided for consideration. If the Commission asks how a resident came to agree to a HELF, the answer needs to be more substantial than a signature on a form.

5. Existing residents need particular clarity

For residents transitioning from existing Additional Services or Extra Services arrangements, providers should clearly set out what is part of the standard service, what is genuinely additional, and what the resident will now pay for through HELF.

Residents and families need enough information to readily understand what has changed and what they are paying for.

6. HELF should not become a “set and forget” charge

Providers need to consider whether the resident continues to be able to use and benefit from the service.

Examples discussed included extended hospital leave and changes in a resident’s condition. Continuing to charge for something the resident cannot reasonably access or use creates obvious concerns.

This reinforces the need for a continuous review cycle, rather than treating the original agreement as sufficient indefinitely.

7. Pricing is not prescribed, but it needs to withstand scrutiny

Providers determine their own pricing, but the clear expectation is that pricing should be reasonable and that older people should have a proper opportunity to understand both the value of what is being offered and its cost.

So the question shouldn’t simply be: “Can the provider charge this?”

It should also be: “Could the provider comfortably explain why this service is additional, why this price represents reasonable value, and why this particular resident has freely chosen it?”

If the answer to the second question is uncomfortable, the first question is the wrong place to stop.

8. Complaints and governance are part of the HELF framework

Providers should make it easy for residents and families to ask questions or raise concerns and, as good practice, provide information on avenues such as OPAN and relevant government channels.

There was also a clear regulatory message that irresponsible practices may result in refunds and further regulatory attention, with governing bodies having an important role in oversight. The provider’s intent and actions were specifically emphasised, and serious malpractice may be treated as serious misconduct, which the Department will look into.

What this means for providers

When establishing or reviewing HELF, providers should be testing at least seven things:

1. Standard vs additional. Is there an indisputable distinction between what must already be provided and what HELF is funding?
2. Consumer value. Does the additional service genuinely enhance the resident’s experience?
3. Choice and consent. Can you evidence genuine choice, without pressure and without any connection to admission?
4. Pricing and bundles. Is pricing fair and explainable, and can residents select what they genuinely want?
5. Ongoing review. Is there a process for leave, changing circumstances, inability to use services, cancellation and refunds?
6. Governance and evidence. Could the organisation demonstrate all of the above if the Commission reviewed the arrangements?
7. Whether HELF is worth it at all. The potential revenue needs to be weighed against the issues the provider invites by commencing HELF, compared with other avenues for improving margin.

One of our biggest takeaways is that HELF should be designed from the resident backwards, rather than from the provider’s desired revenue backwards. If you keep that principle at the centre of any HELF work, most of the other requirements flow logically from it.

How Anchor Excellence can help

Our Complex Business & Finance Advisory practice, working closely with our Risk Advisory team, supports providers to:

• Assess whether HELF is a sound revenue strategy for your organisation, and what it will take to do it well
• Design a HELF offering that can withstand scrutiny across choice, consent, pricing, bundles and governance
• Audit your current HELF or Additional Services arrangements to understand the gaps, then remediate them quickly with continuous improvement built in

If you are considering HELF, transitioning residents from existing arrangements, or want confidence that your current approach would stand up to Commission review, get in touch with our team.