Feedback & Complaints Policy & Procedure - Therapeutic Support Clients

We recognise, promote, and protect our clients' right to comment, compliment and complain. This Policy describes how we receive and respond to feedback and complaints from clients, carers, family members, and other relevant stakeholders in accordance with the National Disability Insurance Scheme (Complaints Management and Resolution) Rules 2018 (Rules).

We maintain a Complaints Management & Resolution System (System) that is relevant and proportionate to the scope and complexity of supports we deliver and the size and scale of the organisation. The system follows principles of procedural fairness and natural justice and complies with the requirements under the Rules.

Scope

This Policy includes clients (past and present), carers, family members, other organisations and community members wishing to provide feedback or lodge a complaint regarding any aspect of the services provided by us (including services delivered on our behalf or subcontracted by us).

This Policy does not cover complaints made by our staff in relation to employment matters - these are defined as work related grievances and are addressed in our Disciplinary Policy.

Key definitions

Complaint is an expression of dissatisfaction, unmet expectation, or frustration by or on behalf of a client, carer or family member regarding any aspect of the quality or delivery of services, policies, procedures or conduct or any other element of the way we do our business, regardless of how it is made.

Complainant is the person or party making the complaint, either directly or through someone acting on their behalf.

Feedback refers to general comments, information (positive or negative) or a suggestion provided by a client, carer, family member or community member regarding any aspect of the way we conduct our business.

Grievance is a cause for complaint regarding any condition of employment or problems in the workplace that the employee feels are unjust or unfair; or a complaint that arises from perceived personal concerns relating to one or more work related interpersonal relationships.

Policy Statements

Each participant is provided with information on how to give feedback or make a complaint, including external avenues, as well as their right to access advocates.

 We foster a supportive and empathetic environment for any person who provides feedback and/or makes complaints.

We look to continuously improve our feedback and complaint arrangements by periodically reviewing our policies and procedures, and outcomes.

We provide, where practicable, opportunities for participants to provide their views on the accessibility of the arrangements.

All workers are aware of, trained in, and comply with the required procedures in relation to complaints handling.

We provide for an easy and accessible process for making and resolving complaints, as well as simple and accessible documentation about how to make a complaint.

We ensure that appropriate support and assistance is provided to any person who wishes to make, or has made a complaint, reminding people that it’s okay to have support when making a complaint and offering support can increase their confidence and reduce anxiety.

Our Responsibilities

We:

value and encourage feedback.

commit to a positive complaints culture.

are accessible and responsive.

uphold the rights of clients to provide feedback including compliments and complaints regarding the support and services they receive from us.

are respectful of complainants.

utilise insights to inform the improvement of services, service delivery and systems.

respect and facilitate the clients right to an independent advocate.

ensure that the safety and wellbeing of clients is prioritised, including taking immediate action to protect children at risk where appropriate.

establish and acknowledgement of resolution(s) sought by the complainant.

endeavour to resolve complaints effectively and efficiently in not more than 28 days of receipt of the complaint.

respect clients right to privacy and confidentiality.

Channels

To ensure our feedback and complaints systems are accessible, we accept complaints, feedback, and compliments received:

verbally (phone or in person) or in writing;

by letter;

by email;

electronically via our website;

electronically via social media; or

anonymously.

Support

Sometimes a person might need support from staff, family, or an advocate to make a complaint or during the complaints handling process.

Clients receiving NDIS services are advised that they may choose to have an advocate speak, act, or write on their behalf and that advocates can be found by using the finder tool on the NDIS Quality & Safeguards Commission’s website.

Clients receiving NDIS services are informed that they may contact the NDIS Quality and Safeguards Commission by phoning 1800 035 544, additional information is available on their website.

All new clients are given an information pack which includes information and contact details to provide compliments and feedback, as well as raise and escalate complaints (including with the assistance of an advocate if the client so chooses).

Procedure

What is a complaint?

Remember, the Policy defines a complaint as an expression of dissatisfaction, unmet expectation, or frustration by or on behalf of a client, carer or family member regarding any aspect of the quality or delivery of services, policies, procedures or conduct or any other element of the way we do our business, regardless of how it is made.

This could be because the client is unhappy with us, something has gone wrong, something is not working well, something has not been done the right way, something makes them unhappy, or because they have been treated badly.

Some examples might include:

Service Quality and Delivery Issues:

o   Inadequate quality of care or service provided.

o   Services not being delivered as per the agreed plan.

o   Inappropriate or unprofessional behaviour by staff.

o   Services not tailored to the participant’s individual needs or preferences.

Communication Problems:

o   Lack of clear, timely, or effective communication from providers or staff.

o   Misinformation or lack of information regarding services, changes, or rights.

o   Language barriers or insufficient use of interpreters and accessible communication methods.

Financial Concerns:

o   Discrepancies in billing or charges for services not rendered.

o   Mismanagement of funding or resources.

o   Lack of transparency about how funds are being used.

Rights and Safety Concerns:

o   Concerns about privacy and confidentiality.

o   Complaints relating to discrimination, abuse, or neglect.

o   Safety issues, including concerns about physical or emotional harm.

Changes in Circumstances:

o   Lack of flexibility in adjusting services or plans when a participant’s circumstances change.

o   Delays in responding to urgent needs or emergencies.

Principles

The person making the complaint, and any person with disability affected by issues raised in a complaint, should be included throughout the process to the extent possible.

We must ensure to involve the person making the complaint, and any person with disability affected by issues raised in a complaint, by communicating with them throughout the complaint management and resolution process in an appropriate way that meets their needs.

A well-handled complaint signals to the person that their opinion is valued, and their feedback has been taken seriously. This interaction can actually improve the relationship between us the complainant.

How we respond to a complaint is just as important as whether or not the complaint is resolved.

Reminding people that it’s okay to have support when making a complaint and offering support can increase their confidence and reduce anxiety.

Steps

1.     Acknowledgement

Upon receipt of the complaint, acknowledge it within 24 hours. Inform the participant that their complaint has been received and will be reviewed.

2.     Record the Complaint

Document all details of the complaint in the Complaints Register (Register). Ensure all information related to the complaint is kept confidential and is only accessible to personnel involved in handling the complaint. The Register contains the following fields, not all of which you will be able to populate at this stage, but all complaints must be recorded.

  Reference

  Date of Complaint

  Date Entered

  Description

  Client name

  What does the client want to happen?

  Action taken

Investigation / Response

Outcome

  Status

Improvement

3.     Initial Assessment

Assign a staff member to manage the complaint, the staff member should have the necessary skills and authority to manage the complaint. Assess the urgency and severity of the complaint to prioritise its resolution. Urgent complaints (such as situations potentially posing a risk to a participant) should be fast-tracked.

4.     Investigation

Collect all necessary information to understand the context and specifics of the complaint. This may involve speaking with the participant, staff members, and reviewing relevant documents. Analyse the information to determine the causes of the issue. This should be done objectively and fairly.

5.     Resolution

Propose a solution to resolve the complaint. If needed, discuss potential resolutions with the participant to ensure their concerns are fully addressed. Once agreed upon, implement the resolution plan. This might involve corrective actions, policy changes, or other appropriate responses. Aim to resolve complaints within 30 days.

6.     Communication

Regularly update the participant about the progress of their complaint. Communication should be clear, concise, and respectful. Once the complaint is resolved, provide a formal written response to the participant detailing the outcome and any actions taken.

7.     Follow-Up

Contact the participant after the resolution to check their satisfaction with the process and outcome. Review the complaint and the resolution process for any lessons learned or opportunities for improvement in service delivery.

8.     Escalation

If the participant is not satisfied with the outcome, inform them of their right to escalate the complaint to an external body such as the NDIS Quality and Safeguards Commission.

9.     Review and Audit

Regularly review the complaints management process to ensure it remains effective and compliant with NDIS standards. Conduct periodic audits to ensure the integrity and effectiveness of the complaint handling process.

The NDIS Quality & Safeguards Commission

The NDIS Quality & Safeguards Commission (Commission) may hear complaints about whether a NDIS funded service has been provided in a safe way and to an appropriate standard. The client may also complain about how we dealt with a complaint.

The complaint will be acknowledged, and a Commission complaints resolution officer will arrange a time to talk to the client to understand the concerns.

The Commission may ask the client for more information to understand the issues involved and any immediate concerns.

There are three main ways the Commission deals with most complaints.

1.     Help the client resolve the complaint themselves by explaining:

their rights and what the NDIS Commission expect us to do.

how to find an advocate. 

how to complain us.

how to contact another agency if they are better suited to deal with the complaint. 

2.     Ask us to work with you to resolve your complaint directly. 

3.     Work with us and the client to find a solution.  In some cases, the NDIS Commission may decide to:

offer to conduct a conciliation.

 require us to give us information or do certain things.

formally investigate the situation.

take enforcement action against us or a worker.

At the end of the complaint resolution process, the NDIS Commission will explain its decision, the information considered that led to the decision, any actions we or the client agreed to take, and what we or the client can do if there is disagreement with the decision.

Where can you go for support?

If you ever have any questions or concerns, or require additional support, please reach out to the Directors.