Complaints & Feedback Handling

2.6 COMPLAINTS AND FEEDBACK HANDLING POLICY

 

Purpose
1 Stop Health Pty Ltd values feedback and complaints from contractors, staff, clients, carers, guardians and others involved with the person with a disability, as a positive at all levels. Feedback and complaints offer management, contractors and staff opportunities to reflect, impact on our organisational reputation within the community and assist to drive organisational change and improve services, products and customer service.
1 Stop Health Pty Ltd believes that people with disability have the same rights as other members of the community to pursue grievances. People with disability may face multiple barriers to making a complaint or providing feedback about their support or services. These include lack of experience asserting their rights as consumers, fear of retribution, negative experiences with complaints systems (including not being believed) and difficulty communicating what happened without support. Additionally, in the case of violence, neglect and abuse, people can face substantial barriers to making a complaint. 1 Stop Health Pty Ltd aims to develop and implement feedback and complaints systems that support utilisation by people with a disability and are inclusive of their capacities, needs and support systems.
1 Stop Health Pty Ltd is committed to consistent, fair, and confidential complaint and feedback handling to resolve issues as quickly as possible. 1 Stop Health Pty Ltd aims to make it easy for people to make a complaint or feedback if they have concerns / positives and will treat all clients making a complaint / feedback equally.

Policy
1 Stop Health Complaint Management and Resolution System will:
• Support all clients / NDIS participants to understand their rights and what they should expect of providers in a suitable format / language,
• Supports all clients / NDIS participants to have the confidence to complain or provide feedback when they experience issues or have suggestions,
• Enable other stakeholders (such as advocates and workers) to make complaints / provide feedback and ensure issues can be addressed when persons with disability are unable or unwilling to make a complaint,
• Ensure that the complaints resolution process includes the person making the complaint; person with a disability that is affected by the complaint and any advocate, carer or guardian affected or involved with the client,
• Ensure that the person with a disability is involved in the complaints process to the appropriate extent/capacity/needs and are supported by advocates and carers as they require,
• Provide ongoing and timely communication to all parties involved in the complaints process via communication methods that meet their needs,
• Support the resolution of complaints when possible; provide reasoning for decisions made; options for review of decisions made during the process and provide an escalation pathway where required (NDIS Commissioner and NDIS Commission Complaint Contact Form),
• Support the collection and review of positive feedback, compliments, and suggestions,
• Enable the identification of systemic issues and drive improvements, including accreditation / auditing requirements and reporting on complaints / complaint systems as required by government agencies / NDIS Quality and Safeguard Commission NDIA Complaints Management and Resolution Rules 2018.
• Identify and report on any complaints, incidents or issues that are reportable (as per the Client Incident Management and Reporting Policy; Mandatory Reporting guidelines and NDIS Incident Reporting and Management Rules 2018).
• Provide support and training to staff, contractors, students, and volunteers to implement, support and manage the complaints resolution and handling processes within the organisation.
• Complaints and Feedback Management and Resolution policies and systems will be reviewed annually,
• Any documentation associated with Complaints and Feedback systems will be kept for a period of 7 years.
• Inform others that Complaints and Feedback documentation can be released to NDIS Commission when requested.

Definition of a Complaint
Complaints are defined as any expression of dissatisfaction or grievance made by a client, advocate, member of the public, staff, or service provider in relation to the service.

1.0 Procedure Complaints

1. Receive and record complaint
2. Acknowledgement
3. Assessment
4. Planning
5. Investigation
6. Response/Resolution
7. Follow-up
8. Review and consideration of systemic issues

1.0 All clients / NDIS participants receiving services from 1 Stop Health Pty Ltd will be provided with information regarding the Complaint Management and Reportable Client Incidents system when they commence services. Including the Service Feedback and Complaints Information Sheet and NDIS Quality and Safeguards Commission – How to Make a Complaint Brochure. Clients will also receive information on Incident Reporting and Management via Incident Reporting and Management Information Sheet and Privacy Policy Information Sheet.
Information will also be available on the website, in the waiting room, upon initial contact with the client, within the Service Agreement / NDIS Service agreement and upon request.

1.1 Complaints and feedback may be received via telephone, in writing, electronic mail (e-mail) or in person by the client, client advocate or client’s representative in person, community organisation; by a member of staff / contractor of 1 Stop Health Pty Ltd and/or anonymously.

1.2 When a complaint is received and/or an incident which needs to be reported is identified, any supports required to facilitate communication and participation by the participant (e.g. supports in languages other than English, braille, audio recording and/or AAC options) will be identified and all reasonable steps taken to have these available.
If clients with a disability require assistance to make a complaint, they may be assisted to access / engage with support services and external pathways throughout the complaints process. These may include but not be limited to:

Advocacy services
Disability Rights Advocacy service (DRAS) 08 8351 9500
Narelle Probert (DRAS) 0497 316 538 nprobert@dras.com.au
Disability Advocacy and Complaints Service 08 7122 6030
advocacyfordisability.org.au

Interpreting services (free)
Translating and Interpreting Service (TIS)
https://www.health.act.gov.au/about-our-health-system/multicultural-health-act/need-interpreter
Medical interpreting services
https://www.dss.gov.au/settlement-services/programs-policy/settle-in-australia/language-services/free-interpreting-service/free-interpreting-service-for-private-medical-practitioners-0

National Relay Hearing Services 1800 800 110
TTY: 1800 555 677
Speak and Listen: 1800 555 727
NDIS Quality and Safeguards Commission 1800 035 544
Website: https://www.ndiscommission.gov.au/ – make a complaint link on site via the Complaint Contact Form

1.3 All reasonable steps will be taken to ensure that:
• A person who makes a complaint, or a person with a disability affected by an issue raised in a complaint, is not adversely affected as a result of the making of the complaint. A risk assessment of client safety, health and wellbeing associated with the complaint is made and appropriate actions implemented.
• Information provided in a complaint is kept confidential and only disclosed if required by law / NDIS Commission or if the disclosure is otherwise appropriate due to risk in the circumstance.
• All staff / contractors will be trained to handle and refer client complaints in a polite, prompt, consistent, positive and constructive manner.

1.4 The Complaints Form / Incident Record forms will be completed by the staff / contractor who initially receives the complaint.

1.5 Where possible the person receiving the complaint / contractor may initiate and assist in resolution of the complaint or feedback.

1.6 Complaints will be referred to the Directors of 1 Stop Health within 24 hours of receipt.

1.7 The Directors / contractor will ensure appropriate support and assistance is provided to any person who wishes to make, or has made, a complaint. This may include facilitating communications in languages other than English, or the use of a communication support such as AAC or braille using available publicly funded options. The person receiving the complaint or reporting the incident may assist the client to complete the form, for example by writing the details on the complaint form as verbalised by the client/ their representative.

1.8 Documentation or a record of the person’s agreement with the report should be gained e.g. by signing the document, or video-recording verbal agreement, or videoing the persons non-verbal responses.

1.9 Once a client has given an indication of an issue/concern, there will be an immediate attempt to determine the exact nature of the concern/problem and where possible correct or resolve the issue.

1.10 If a concern/problem cannot be resolved immediately, and/or the client or their representative is not satisfied with the outcome, the Director(s) will provide the client with the Feedback and Complaints Sheet. This will provide the client with the process for making a complaint and options available to them.
If they would like to proceed, the person making the complaint will be provided with a Complaint Form.

1.11 The Director will:
• Provide the person with an acknowledgment of the complaint via Acknowledge Receipt of Complaint template within 5 business days of receiving the complaint,
• Record the complaint on a Complaints Record form and in the Complaints Register,
• Assess and investigate the complaint,
• Ensure that procedural fairness is afforded to all involved in the complaint,
• Endeavour to resolve the complaint in a fair, efficient, and timely manner.
• Take appropriate action in relation to the issues raised in the complaint,
• Report back to the client/their representative regarding the decision and the reason for the decision of the complaint ideally within 21 business days of receiving the complaint.
• Provide appropriate support and assistance for the client/ their representative, to contact other complaint mechanisms such as the NDIS Commissioner if they are not satisfied with the outcome of the complaint.
• Provide direct contact details for the NDIS Commissioner if the client or person does not wish to discuss the issue with the Directors.
NDIS Quality and Safeguards Commission 1800 035 544
• Website: https://www.ndiscommission.gov.au/ – make a complaint link on site via the Complaint Contact Form

1.12 1 Stop Health Directors must ensure the person making the compliant, the person with a disability whom the complaint is related to and their support system are:
• Appropriately involved in the resolution of the complaint; and
• Kept informed of the progress of the complaint, including any action taken, the reasons for any decisions made, and options for review of the decision in relation to the complaint.
• Once a decision/outcome has been concluded (ideally within 21 working days), the Directors will phone the client and advise them of the findings and the reason for any decision being made. If alternative forms of communication have been selected or supports to facilitate communication of this feedback are required, these will be undertaken to ensure feedback is conveyed appropriately.
• If the client is satisfied with the outcome, the Director will record the details on the Complaint Record Form, complete a client letter – Outcome in Favour of Client, take a photocopy and post the original to the client. A copy of the letter with the other supporting documents will be filed in 1 Stop Health’s Complaints folder with the completed Complaint Records Form and the Complaints Register will be updated as complete (include: date finalised). Complaint documents will also be kept within the client record.

1.13 If the complaint is not resolved to the client’s satisfaction, the Directors will advise the client that they have the right to contact other agencies to seek further resolution and provide them with details of their options. These include the :
NDIS Quality and Safeguards Commission 1800 035 544
Website: https://www.ndiscommission.gov.au/ – make a complaint link on site via the Complaint Contact Form
NDIA Reportable Incidents: reportableincidnet@ndiscommission.gov.au

• SA Ombudsman on ph: 08 8226 8699 or toll free 1800 182 150 or email: ombudsman@ombudsman.sa.gov.au

• Australian Government Office of the Privacy Commissioner for complaints relating to the Privacy act 1988 visit: http://www.oaic.gov.au/privacy/privacy-complaints

• Disability Advocacy and Complaints Service – ph: 1800 555 630

• Australian Health Practitioners Regulation Agency ph: 1300 419 495 or https://www.ahpra.gov.au/ for online complaints process.

• Health and Community Services complaints commissioner ph: 82268666

• Australian Human Rights Commission ph: 1300 656 419 Online: www.humanrights.gov.au

• South Australian Equal Opportunities Commission (for complaints relating to discrimination) ph: 085 82071977 Online: www.eoc.sa.gov.au

• 1 Stop Health Directors will also complete a client letter – Outcome not in Favour of the Client, take a photocopy/scan and then post the original to the client. They will attach a copy of the letter with the other supporting documents and store this in the client’s file.
• The client’s letter will detail the reasons why he/she is not satisfied with the complaint resolution proposal and should set out his/her expectations and desired outcomes for the dispute to be satisfactorily resolved.
• Record the client’s dissatisfaction with the complaint outcome on the Complaints Record Form and Complaints Register. File a copy of all the relevant documentation in the Complaints Folder.

1.14 Directors may appoint an external agency or person to assist management of a complaint made against the Directors or if the client / complaint party does not wish to resolve the issue with the Directors.

1.15 Positive feedback in the form of cards, notes, social media comments, thankyou’s, small gifts, recognition will be recorded in the Feedback register and saved. A feedback form will be offered when requested or when feedback is sought about specific services and programs.

Recommendations or supporting comments may be used in advertising as per allied health legislative guidelines and codes of conduct.

2.0 PROCEDURE FEEDBACK MANAGEMENT

2.1 Receiving feedback
> Feedback can be accepted by any staff, contractor, student or Directors and may include:

> Formal feedback: primarily received through service/program and/or management processes. This may include feedback collated through feedback forms, surveys and evaluation processes. Feedback received in this way should be managed in accordance with the organisation Program Management Policy.
Formal feedback may also be received via phone, email or face-to-face meetings. This may be identified as formal feedback by the person submitting the information.

> Informal feedback: can be received through face-to-face conversation, telephone, email or letter by any staff member. Feedback should be acknowledged by the receiver and the appropriate response provided where required. Informal feedback can be valuable in organisational and program development, planning, and review.

> Feedback regarding staff: whether formal or informal, feedback is reported to the relevant staff member and their supervisor and discussed in supervision/professional development review where appropriate.

> Feedback regarding services/programs: formal and informal feedback about 1 Stop Health Pty Ltd programs, services and activities is to be raised at Directors, staff or consortium meetings where relevant. Staff involved in the activity that has generated the feedback should be notified on receipt of that feedback.

> Negative feedback or concerns: Managing negative feedback appropriately is of great importance in promoting the organisation’s reputation for valuing all feedback and will assist in reducing the likelihood of a complaint being lodged. No issue is too small.

The staff member in receipt of the negative feedback or concern, will raise the issue with the Director and the Complaints procedure will be followed.

> Feedback received in a non-acceptable manner: In some circumstances feedback may be received where the person providing feedback is unprofessional, and their behaviour is inappropriate or abusive. Staff members in receipt of any feedback or complaints should retain a professional demeanour and handle the matter in line with the organisation’s Code of Conduct. The staff member informs Directors of the situation.

2.2 Responding to feedback
All feedback submitted to 1 Stop Health Pty Ltd should be acknowledged appropriately and in a timely manner. The recipient of feedback acknowledges receipt of feedback immediately or 5 days if written. Depending on the nature of the feedback, other responses may include:
– Thanking the individual/service
– Informing the individual/service of its value
– Explaining how the information will be utilised (i.e. compliments may be used in reporting; constructive feedback or suggestions may assist in future planning or review activities).

In some cases, feedback (for example, suggestions) may require a further response or resolution. Staff members in receipt of the feedback will also provide guidance on the next steps in the process. This may include provision or completion of a Feedback form including:
– Timeframe for response
– Request for preferred contact method
– Name and contact details of the staff member who will be responding
– Request for supporting information (when relevant)
– Organisational follow-up actions (e.g. raise the suggestion/concern at the staff, consortium or team meeting).

The level of response required is dependent on the assessment of the feedback provided, the method of receipt and any explicit or implicit requests for a response or resolution.

2.3 Recording feedback
When receiving feedback, staff members are required to complete a Feedback Record Form. This document records factual information that can be supported by evidence or should note that the information is not yet substantiated.

The staff member in receipt of the feedback, or the Directors are responsible for recording the feedback in the Feedback Register.

Negative feedback about staff / contractors is to be referred directly to the Directors and when deemed appropriate, documented in the staff member’s personnel file. Personnel files are to be stored in accordance with Human Resources Policies.

2.4 Organisational feedback forms
Feedback forms are available to clients, contractors, stakeholders and the general public. These forms constitute physical evidence of feedback and should be saved as PDFs in the relevant folder. Hard copy evidence is to be stored with relevant program/project/service information and with the Complaints / Feedback register.

Information to be logged in the organisation feedback form includes:
– Date of feedback
– Contact details, including name, phone and email
– Feedback topic (e.g. program activity, organisation communications)
– Feedback content (brief description).

Information to be logged in the organisation feedback record form includes:
– Date of receipt
– Feedback number
– Received by (staff member)
– Method of receipt (e.g. phone, face-to-face)
– Feedback topic (e.g. program activity, organisation communications)
– Feedback content (brief description)
– Feedback type (i.e. formal/informal)
– Supporting documents (where relevant list and hyperlink to evidence of feedback)
– Response required
– Follow-up and/or other comments.

Feedback register.
Information to be logged in the organisation’s feedback register includes:
– Date of receipt
– Feedback number
– Received by (staff member)
– Method of receipt (e.g. phone, email)
– Feedback topic (e.g. program activity, organisation communications)
– Feedback type (i.e. formal/informal)
– Status.

3.0 Documentation

3.1 1 Stop Health will provide copies of this Complaints and Feedback Policy to:
• All clients engaging with services and any persons with disability receiving NDIS support or services and their families, carers and advocates;
• each person employed, contractors or otherwise engaged by the practice.

4.0 Monitoring, and Reporting Complaints

4.1 All records in regard to Complaints must be kept for 7 years from the day the record is made.

4.2 It is important to record the complaints information on the Complaints Register to assist management in measuring effectiveness in a number of areas. The information can be used to:
• identify and address recurring, or systemic issues,
• identify training requirements, and
• highlight product or internal control weaknesses, and
• report information relating to complaints to the NDIS Commission, accreditation / audit agencies or government body, if requested.

4.3 1 Stop Health Pty Ltd will analyse complaints data regularly to identify any trends in the complaints received by the Practice and then make changes to policies and procedures as required to reduce the possibility of repeat complaints.

5.0 Roles, Responsibilities, Compliance and Training of Staff

5.1 The Directors of 1 Stop Health are responsible for ensuring that all persons engaged under the practice to all client types including NDIS clients have been trained and comply with this Complaints Management and Resolution System.

6.0 Complaint and Feedback Policy Review and Authorisation

6.1 1 Stop Health will review this Complaint Management and Resolution System yearly to ensure its effectiveness.

6.2 1 Stop Health Pty Ltd Directors have authorised this policy.

7.0 Referring Complaints

7.1 Complaints will be referred or notified to any other bodies in accordance with any requirements under relevant Commonwealth, State or Territory laws.

For example:
• Child protection agencies
• Work Health and Safety agencies
• Consumer Protection Agencies, and
• Medical or professional accreditation or monitoring bodies.
• NDIS Quality and Safeguards Commission

7.2 1 Stop Health Pty Ltd / contractor and individual allied health practitioner insurance bodies will be notified as required regarding complaints made and resolutions achieved.