Client Feedback and Complaints Management Policy
| Policy area | Service Delivery |
| Document type | Policy |
| Applicable to | Beyondlimits Care & Support Services |
| Version | 001 |
| Date approved | 19/08/2024 |
| Approved by | Managing Director |
| Next review date | Every 12 Months |
| Related policies | Incident Management Policy Emergency and Disaster Management Policy Client Health and Wellbeing Policy Client Living Alone and Receiving Personal Care from a Sole Worker Policy Transition of Care Between Different Environments Policy Safeguarding Against Violence, Abuse, Neglect, Exploitation and Discrimination Policy Duty of Care Policy Client Advocacy Policy Consent Policy Diversity Policy Support Planning Policy Service Access and Exit Policy Service Delivery Policy Information Management Policy Privacy Policy Conflict of Interest Policy Continuous Improvement and Quality Management Policy |
| Authority | NDIS Act 2013 NDIS Practice Standards and Quality Indicators NDIS Code of Conduct NDIS (Complaints Management and Resolution) Rules 2018 NDIS (Procedural Fairness) Guidelines 2018 UN Convention on the Rights of Persons with Disabilities UN Convention on the Rights of the Child Aged Care Act 1997 Aged Care Quality and Safety Standards Aged Care Code of Conduct Privacy Act 1988 |
PURPOSE
The purpose of this policy is to explain our organisation’s commitment and approach to client feedback and complaints management.
SCOPE
This policy applies to all our workers (employees, contractors and volunteers).
DEFINITIONS
| Term | Definition |
|---|---|
| Complaint | Expressing dissatisfaction with a support or service where standards or expectations have not been met. |
| Open Disclosure | The practice of acknowledging the complaint, expressing regret to the person making the complaint that standards or expectations have not been met, finding out what happened, how and why and seeking to learn from the experience and make improvements. Note: Expressing regret does not mean an admission of guilt. |
| Procedural Fairness (‘Natural Justice’) | Legal term for acting fairly in administrative decision-making. |
| Reprisal | The act of retaliation — to ‘pay back’ someone who has actually or allegedly ‘wronged’ you. |
| Retribution | The act of taking revenge — punishment inflicted motivated by personal vengeance. |
CONTEXT
Our organisation recognises the importance of an effective feedback and complaints management system to provide our clients with safe and quality care and continually improve our service delivery and business operations. We will maintain a feedback and complaints management system that:
- is proportionate to the size and scale of our organisation and the scope and complexity of supports provided;
- complies with relevant legislation, regulations, standards and principles — including principles of procedural fairness (‘natural justice’).
- is fair, consistent and transparent;
- upholds clients’ human rights — including their right to privacy, confidentiality, dignity and respect;
- promotes clients’ right to choice, control and self-determination;
- encourages and supports client independence and capacity-building, where possible;
- provides cultural and language-accessible modes and methods for clients to submit feedback and complaints; and
- fosters a resolution-based culture of open disclosure without discrimination, reprisal or retribution.
POLICY STATEMENT
#1
Encouraging and Acknowledging Feedback, Compliments and Complaints
- We will ensure clients are aware of their right to provide feedback and make a complaint (without fear of reprisal or retribution), both internally in our organisation and also externally to a regulator, and support them to do this if requested.
- We will welcome all complaints, concerns, compliments and suggestions and view them as opportunities for continuous improvement.
- We will support clients to access an advocate, language services or any other aid or service they need to raise and resolve a complaint.
- We will acknowledge the complaint verbally and/or in writing, expressing regret that standards or expectations have not been met, or express verbal gratitude to acknowledge a compliment, in a way that is culturally respectful and in a language, mode and method the client is most likely to understand.
#2
Response Actions
- We will take required action(s) to address immediate client risks, issues or concerns.
- We will conduct internal and external incident reporting as required.
- We will document the feedback/complaint in the Complaints Register.
- We will discuss our response actions with the client and / or family / alternate decision-maker / advocate and encourage their involvement in improving our services.
- We will inform the client if their rights or interests may be adversely affected in a direct and specific way because of the complaint, or something relating to the complaint.
- We will ensure any adverse decision outcome(s) for the client is/are based on the facts and the record of decision is clearly and accurately documented in the client file and in the Complaints Register.
#3
Communication and Collaboration
- We will conduct all discussions with the client and/or family/alternate decision-make/advocate with sensitivity, courtesy and respect.
- We will communicate and collaborate with the client and/or family/alternate decision-maker/advocate throughout the complaints process.
#4
Continuous Improvement and Quality Management
- We will seek to learn from feedback and complaints and continually improve our service delivery processes.
- We will review and analyse feedback and complaints raised to identify systemic issues and take follow up action(s) as required (changes to policy and procedures, worker rostering, supervision and training, technology and communications).
- We will report outcomes of complaints/incident investigations to both the client and other stakeholders (including relevant workers) and ensure this is documented in our quality management system as part of the continuous improvement process.
- We will regularly review and improve the effectiveness of our feedback and complaints management system.
#5
Reviewing and Monitoring Processes
- We will conduct audits to review and monitor our feedback and complaints management process and make any required adjustments.
- We will maintain a Complaints Register and a Continuous Improvement Register with details, actions and outcomes of complaints and suggested improvements.
#6
Information and Record-keeping
- We will ensure information and records are accurate and up to date.
- We will ensure the client has provided us with all required written consents.
- We will store the information securely to ensure privacy, dignity and confidentiality and make sure it is accessible to the client and only other stakeholders authorised to access it.
#7
Worker Training and Supervision
- We will maintain a skilled and trained workforce, which is aware of clients’ right to complain and our complaints-handling process.
- We will maintain processes to adequately monitor and supervise workers.
SUPPORTING DOCUMENTS
Related procedures and forms include:
- Complaint and Feedback Form
- Anonymous Complaint and Feedback Form
- Complaints Process Checklist
- Complaint Register
- Continuous Improvement Plan Register
- Incident Investigation Form — Final Report
- Incident Report
- Incident Register
- Risk Assessment Form
- Risk Management Plan Register
- Client Feedback and Complaints Management Procedure
- Safeguarding Against Violence, Abuse, Neglect, Exploitation and Discrimination Procedure
- Incident Management Procedure
- Reportable Incident Management Procedure
- Emergency and Disaster Management Procedure
- Transition of Care Between Different Environments Procedure
- Client Living Alone and Receiving Personal Care from a Sole Worker Procedure
- Support Planning Procedure
- Service Access and Exit Procedure
- Service Delivery Procedure
- Client Advocacy Procedure
- Management of Data Breach Procedure
- Continuous Improvement and Quality Management Procedure
RESPONSIBILITIES
Managing Director is responsible for:
- maintaining this policy, its related procedures and associated documents;
- ensuring the policy is effectively implemented across the service;
- monitoring workers compliance with the requirements of this policy; and
- ensuring training and information is provided to workers to carry out this policy.
All workers are responsible for complying with the requirements of this policy.
COMPLIANCE
Deliberate breaches of this policy will be dealt with under our misconduct provisions, as stated in the Code of Conduct Agreement.
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