Aged care is consolidating: workforce due diligence when you acquire a provider

HammondCare is acquiring Anglicare Sydney's community home care business, with completion targeted for 2 November 2026. Around 1,800 Support at Home clients and more than 1,400 Commonwealth Home Support Programme clients move across Greater Sydney and the Illawarra, taking HammondCare past 11,000 home care and CHSP clients. Many of the Anglicare staff supporting those clients are expected to move with them.

A much larger transaction may be coming. On 27 August 2026 the sector press reported, citing The Australian, that Bupa has put its Australian aged care portfolio back on the market, appointing Morgan Stanley for the Australian operations and Jarden for New Zealand, with industry sources quoted in that reporting putting the combined portfolio above $2 billion. Bupa operates 57 residential aged care homes in Australia, 24 of them in NSW and 21 in Victoria, alongside 40 in New Zealand. Bupa has not confirmed a process, and an earlier attempt to sell parts of the portfolio in 2022 was abandoned in difficult market conditions, so this is reported rather than settled. If it does proceed, a 57 home residential portfolio is a workforce transfer of a different order to a home care book.

That is the shape of Australian aged care right now. Support at Home rewards scale, providers who cannot reach it in the community are selling the community book, and residential portfolios are changing hands at the same time. Every one of those transactions transfers a workforce, and the workforce is where the undisclosed liability usually sits.

On completion day, their workforce is your legal responsibility

The screening rules do not turn on tenure. A worker who transfers to you at completion needs the same thing a worker you hired that morning needs, from the first shift they deliver under your approval. There is no allowance for the fact that they have been doing the same job for the same clients for six years.

That is a straightforward statement of the rule, and it is also the part that gets deferred in a transaction, because integration planning tends to run on payroll, rostering and client continuity. Screening is assumed to be in order because the seller was a regulated provider too.

Two screening options, and a seller's register will not tell you which

For aged care worker screening there are exactly two acceptable outcomes: a National Police Certificate issued in the last 3 years, or a current NDIS Worker Screening Clearance. There is no third option, and AHPRA registration is not screening for these purposes.

A typical seller's register has one column for police check and a tick in it. That tick cannot distinguish between a certificate issued four months ago and one issued four years ago, and the second is outside the limit. It also cannot tell you whether a worker holds a clearance instead, in which case the police history is already inside it and you should not be chasing a separate document.

Ask for the issue date, not the fact of holding. If the answer comes back as a tick, treat the whole register as unverified.

What to ask for in the data room, per worker

A workforce schedule is worth more than a headcount, and it has two halves: what every worker needs, and what follows from the role they hold.

Ask for these against every person delivering care in the business you are buying:

• Full name and the role they perform, including whether they enter a client's home.
• Police certificate issue date, or NDIS Worker Screening Clearance number and expiry, with a clear statement of which applies to that person.
• Evidence of Code of Conduct acknowledgement, and any statutory declaration held.
• Employment status: direct employee, casual, subcontractor, or supplied by an agency.
• Any worker currently subject to a complaint, investigation or restriction.

Then ask for the set that follows the role, which is where a schedule built around screening usually stops:

• The qualification. Certificate III in Individual Support (Ageing) for most direct personal care roles, a Certificate IV or a nursing qualification for senior and clinical ones. Ask for the certificate and the issuing registered training organisation, not a job title that implies one.
• First aid and CPR. CPR is commonly refreshed every 12 months and first aid roughly every three years, which makes this the line most likely to have lapsed quietly across a book nobody was watching during a sale process.
• Manual handling, and infection prevention and control. Usually annual in-service training, and usually the worst evidenced, because it is delivered internally and recorded in whatever the seller happened to use.
• AHPRA registration number and expiry for every registered health practitioner.
• Role-specific competencies: medication assistance, restrictive practices where the role involves them, and the NDIS Worker Orientation Module where the same workforce also delivers disability supports.

That second list is the reason the role mapping in the first one matters so much. The requirement set is a function of the role, so a schedule that names people without reliably naming what each of them does cannot be tested for gaps at all. You are left comparing documents against an assumption.

A residential portfolio adds a further dimension. Registered and enrolled nursing coverage is contracted for and reported on, so you need registration mapped to the shifts it covers rather than to a list of names. It is also the one item on either list you can check yourself, against a public register, instead of taking the seller's word for it.

Then ask the question no schedule answers on its own: which of these has the seller confirmed since the day it was collected.

Contractors and labour hire transfer with the book, even when employment does not

Home care runs on a mixed workforce. Subcontractors, agency staff and platform workers deliver funded services under the provider's approval, and the worker definition reaches anyone entering a client's home in a role connected to funded care.

Those engagements usually continue past completion, because the client relationship does. The evidence for them sits with the agency, not the seller, which makes it a separate diligence request and one that is easy to leave off the list. We cover who carries the obligation in screening subcontractors and labour-hire workers.

The gap rate is the number that shapes your first 90 days

Every acquisition of a care workforce has a gap rate: the proportion of transferring workers whose evidence is missing, expired, or unverifiable from the records handed over. It is never zero, and it is worth measuring before completion rather than discovering it in the first audit under your name.

Knowing it early turns an unbounded risk into a work plan with a number attached, and it is a legitimate thing to price.

Authoritative sources

• Aged Care Act 2024
• Aged care worker screening requirements (Department of Health, Disability and Ageing)
• Aged Care Quality and Safety Commission

Where a workforce bureau fits

The reason a workforce transfer is painful is that each provider has built its own private copy of the same facts about the same people. When the book moves, the copy has to be rebuilt from whatever the seller kept, and the rebuild is where the gaps appear.

A bureau is the other arrangement: one maintained record of a worker's checks that many organisations can rely on, instead of the same person being checked from scratch by every provider they work for. The worker holds their Career Passport and decides who sees it, so a worker who moves employers brings the record with them rather than leaving it behind in a system you no longer have access to.

Practically, an acquirer can import the workforce they are taking on and have the compliance engine test each person's records against what their role requires before completion day, so the gaps are named in advance rather than found later. Identity and work rights are verified by Koora, and so is AHPRA registration. Ban registers are monitored continuously. Nothing else on either list has a register to query, from the police certificate and the NDIS clearance through to the qualification, first aid, CPR, manual handling and infection control, so the engine checks each one against the role's requirements and tracks its expiry, and a person reviews the documents themselves once a worker shares their passport or through the Crew add-on.

Koora pre-clears. The legal responsibility for who you engage to deliver care stays with you, on completion day and every day after it. See also audit-ready in aged care.