Australia's virus aged care death rate is among the highest in the world, at 68 per cent, counsel assisting the commission Peter Rozen QC said on Monday.

As of Sunday, 203 of the nation's almost 300 deaths had been in aged care.

He said while much had been done to prepare the national health system, neither the Federal Health Department nor aged care regulator developed a sector-specific plan.

Mr Rozen said aged care was offered no virus advice from either body from June 19 to August 3, a "crucial period" in the pandemic when cases in Victoria spiked.

He said there was confusion about processes and regulator, the Aged Care Quality and Safety Commissioner, lacked sufficient power to conduct investigations.

"The COVID-19 pandemic has starkly exposed all of the flaws of the aged care sector," Mr Rozen said.

Federal and NSW governments were at a "stand off" early in the deadly outbreak at Sydney's Newmarch House over whether to hospitalise residents, the commission heard.

Mr Rozen said meeting records showed NSW Health in April had a preference not to move virus-positive residents into hospital to avoid setting "a precedent" around transfers.

Of 37 positive residents, two were transferred to hospital. One of those died, with another other 16 fatalities occurring at the home.

"To put it very directly, older people are not less deserving of care because they are old," Mr Rozen said.

Anglicare Sydney, which runs Newmarch House, had little or no say in whether virus-positive residents would be transferred to hospital, he added.

Mr Rozen said there was a lack of high-level infection control expertise at Newmarch House, which adopted a "hospital in the home" approach, until at least a fortnight into the outbreak.

A manager deployed to help Newmarch House from BaptistCare, the operator of Dorothy Henderson Lodge which also experienced a deadly outbreak, said staff management was a challenge with workers quarantined.

"They were coming (to Newmarch) from so many areas with varying competencies," Melanie Dicks said.

"We had new staff that didn't fully understand what hospital in the home model was. We needed to continually orient those staff as well."

Six residents at northern Sydney's Dorothy Henderson Lodge died from the virus, with 13 of the home's 16 cases sent to hospital.

Ms Dicks said hospitalisation helped the facility better contain the virus and manage staffing.

The aged care royal commission is holding hearings over three days to examine the virus response but Victoria's outbreak is not part of the scope due to its evolving nature.

Mr Rozen said the commission had received hundreds of submissions, some of which refer to inadequate staff infection control training and lack of access to personal protective equipment.

Australian Associated Press