Now that the Disability Royal Commission (DRC) has released its final report, we will be publishing some blog posts on a number of the report’s key themes.
Our posts are intended to help providers understand the changes to the disability system that the DRC is recommending, so that they can consider whether they need to adjust or improve how they provide services. It is also a great time for providers to review their policies and procedures. Note that the Australian Government has not yet accepted the recommendations of the DRC, so they are subject to change further down the track.
This first post is about complaints management, and how providers can get on the front foot to ensure complaints processes are what they should be.
Complaints management principles
Recommendation 11.5 suggests that states and territories develop specific guidelines to help organisations implement complaint handling systems which are accessible and responsive to people with disability.
The DRC outlined ten core principles which the guidelines should reflect, which are:
- creating a rights-focused complaints culture;
- encouraging people with disability and others to speak up;
- making adjustments to enable participation;
- supporting the person with disability, their family and others in complaint processes;
- respecting complexity, diversity and cultural difference;
- providing clear information about how to complain, and multiple pathways to complain;
- working respectfully and effectively alongside police;
- conducting safe and inclusive investigations, that are trauma-informed;
- providing tailored outcomes and redress; and
- using complaints data to drive continuous improvement in service provision and complaint handling.
Barriers and accessibility in complaints and feedback
One of the key concerns outlined by the DRC was the lack of accessibility in complaints systems. They raised a series of concerns related to things such as:
- inaccessible policies and processes,
- a lack of options for raising concerns,
- potential victimisation, and
- fear of not being believed or treated or taken seriously, among other things.
To ensure that your organisation’s complaints management does not create barriers, regularly review your policies and procedures and check that they are in line with (and promote) the principles of natural justice.
It is also important to ensure that policies are well communicated and can be easily understood. For example, adopting an Easy English complaints policies which addresses the communication needs of participants can assist in making your complaint handling processes easier to understand.
Strengthening complaints systems
The Executive Summary of the DRC report contains recommendations for measures which NDIS Providers can implement to strengthen their existing complaints management systems, including the following:
- Creating a dedicated complaints management team or individual
This team or individual should be separate from those delivering services. Their primary role is to increase the engagement with participants and their support networks to ensure that complaints are addressed appropriately. - Prioritising complaints based on risk
This involves assessing each complaint separately to determine its severity, and using a triage system to address complaints which have the most potential risk to participants. - Establishing lines of communication
A common theme from the DRC’s investigation of complaints systems is confusion arising from lack of communication. This includes participants not knowing whom to contact, as well as not feeling comfortable to speak up. - Record keeping
Strong record keeping practices, including documenting the conclusion and resolution of complaints, are central to good complaints management. - Organisational culture
Developing a culture that encourages and welcomes feedback is essential to complaints management, and will help inform continuous improvement activities.
Responding to complaints
The DRC stressed the importance of adequately responding to complaints and concerns. Providers should acknowledge the complaint when it is made, and actively involve participants and their families in the investigation and resolution of a complaint.
Poor communication between service providers and participants can result in feelings of distrust and anxiety.
To address this, providers should communicate regularly with participants about the progress of their complaint and ensure that participants are aware of their rights in relation to complaints.
How we can help
We have a number of resources to help providers with complaints management:
- Policy: Complaints Management
- Info: Complaints Management
- Policy: Complaints (Easy English)
- Policy: Child Safe Complaints Management
- Template: Complaints Register
- Template: Complaints Information for Clients
- Template: Complaint Process Tracking Form
- Template: Complaint Submission Form
- Template: Complaint Response Letter
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