Complaints Management Policy

1. Policy Statement

UnitingCare Wesley Bowden (UCWB) welcomes and values complaints and has a strong commitment to responding to and resolving complaints. UCWB recognises that the effective management of complaints is critical to organisational improvement.
Complaints provide the opportunity for UCWB to address concerns and issues in a fair and just manner and build an environment of accountability and transparency across the organisation.

2. Aim

The aim of this policy is to ensure:

  • fair, accountable, transparent and responsive management of complaints
  • complaints are handled promptly and as close to the source as possible
  • effective monitoring of complaints
  • identification and implementation of business improvement opportunities.

3. Scope

This policy applies to all staff (employees, volunteers and contractors) and Board members.

This policy does not apply if the subject of the complaint relates to:

  • a workplace grievances involving employees
  • complaints made under the Whistleblower Policy
  • matters better managed under other regulation, legislation or via criminal investigations.

4. Definitions

Complaint – An expression of dissatisfaction with a service and/or decision of the organisation.
Complainant – The person making the complaint.
Complaint manager – The person making the complaint (may be the client or another person making the complaint on their behalf).

5. Policy Principles

UCWB’s stakeholder feedback processes form part of the organisation’s quality management system. UCWB is committed to using the information gained through complaints to continuously improve the organisation.

Any person or organisation involved with UCWB, or affected by its operations, has the right to give feedback or make a complaint.
UCWB is committed to responding to complaints raised in a fair and just manner with accountability and transparency.

The organisation’s complaints management processes are underpinned by equitable, objective and unbiased processes ensuring appropriate levels of confidentiality are maintained.

UCWB will refer or notify complaints to external bodies as required by legislation and contracts.
Staff receiving a complaint are responsible for ensuring that it is resolved or escalated promptly, according to the organisation’s complaints management processes.

There is ‘no wrong door’ for complainants. Complaints will be actioned regardless of the manner in which they are received.

No complainant will be disadvantaged as a result of making a complaint.

The principles of AS/NZS 10002: 2014 Australian/New Zealand Standard™ Guidelines for complaint management in organisations, guide this Complaints Management Policy and the Complaints Management Procedure.

6. Accessibility of Complaint Process

This Complaints Management Policy and the Tell Us What You Think brochure informing consumers and others how to provide feedback including complaints are available to the public on the UCWB website.

Copies of the brochure are displayed in reception areas at UCWB offices and are provided directly to consumers who have an ongoing relationship with UCWB.

7. Complainant Rights and Responsibilities

7.1 Rights

Any person making a complaint can expect that UCWB will:

  • Deal with the complainant in a respectful, fair and objective manner adhering to the principles of natural justice in the management of the complaint.
  • Provide advice regarding the complaints process.
  • Ensure that it is easy to make a complaint and there is support and assistance to enable a person to make a complaint.
  • Provide help to those who may have difficulties representing themselves; including arranging access to interpreters, aids or advocates and documenting the complaint in writing where circumstances warrant.
  • Advise complainants about external complaints mechanisms such as the Aged Care Quality Agency, National Disability Insurance Scheme Quality and Safeguards Commission, Education and Early childhood Services Registration Standards Board of SA.
  • Resolve the issues or concerns as quickly as possible and ensure the complainant is regularly informed of progress.
  • When a complaint is not resolved at first point of contact complainant will receive:
    • notification of the person investigating within 2 business days
    • an update at least every 5 business days
    • resolution within 2 weeks where possible.
  • Where the complaint is reasonable, ensure an appropriate solution.
  • Provide clear information about the action taken and the reasons for that action.
  • Provide information about any further avenues of review or appeal when the complaint is not resolved to their satisfaction.

7.2 Internal Review

If a complainant is not satisfied with the management or resolution of their complaint they can ask UCWB to conduct a review. They can make this request by phone, in person or in writing.

UCWB aims to respond to all requests for internal review within 10 business days of the request being made.

The executive manager of the division providing the service the complaint relates to will ensure that internal reviews are conducted in accordance with the Complaints Management Procedure and will decide on the response to the complainant.

7.3 Responsibilities

Complainants can assist our staff to resolve their complaint by:

  • clearly identifying their issues of complaint and providing all relevant information regarding their complaint
  • assisting with any requests for information, enquiries or investigations in the time frames agreed
  • showing respect to our staff as they work to resolve the complaint.

Complainants may make anonymous complaints; however, where the information supplied is insufficient to allow thorough investigation of the issue, UCWB will not be able to process the complaint.

8. National Disability Insurance Scheme (NDIS) Complaints

UCWB will take reasonable steps to inform any complainant receiving services under the NDIS that they can also raise the complaint with the NDIS Quality and Safeguards Commissioner.

UCWB will provide support and help to the complainant in contacting the Commissioner.

9. Recording, Monitoring and Reporting

Complaints are recorded on the Feedback Form and in the Stakeholder Feedback Register and information on the management of a complaint may also be recorded in the client’s file. Records relating to complaints will be retained for a minimum of seven years.

All complaints are recorded within the Stakeholder Feedback Register and trends reviewed and reported to department managers, the Executive and the Board regularly in accordance with the Complaint Management Procedure.

Continuous improvement actions arising from a complaint are recorded within the Continuous Improvement Register which is subject to monitoring and reporting in accordance with the Quality Management Policy.

The Chief Executive will ensure that UCWB’s Child Safe Environment Statement is updated with the relevant SA government agency upon any changes to the Complaint Management Policy or Procedure within 10 days of adoption.

10. Training

Staff will be trained in the application of the UCWB complaints management system including in the corporate induction session for new staff.

11. Complaints System Review

The UCWB system for managing complaints will be reviewed regularly; reviews may be included in the Quality Management Schedule or be conducted as internal reviews within a department or division.

12. Responsibilities

All staff

  • Help a complainant to make a complaint, when requested.
  • Follow the Complaint Management Procedure.

Complainant

  • Clearly identify their issues of complaint.
  • Provide all relevant information about their complaint to the best of their ability.
  • Co-operate with any requests for information, enquiries or investigations.

Board

  • Receive notice of complaints posing serious breaches or risks.

Chief Executive

  • Ensure that mandatory notification and/or reporting of complaints to external agencies occurs where required.
  • Provide updated Child Safe Environment Statement to the relevant SA government agency within 10 days of any modification of this  policy or its associated procedure.

Executive

  • Receive complaints trend reporting.

Executive manager

  • Ensure internal reviews are conducted in accordance with the Complaints Management Procedure.

Department manager

  • Ensure all complaints are recorded on a Feedback Form and in the Stakeholder Feedback Register.
  • Receive and respond to complaints trend reporting.
  • Ensure continuous improvement actions are recorded on the Continuous Improvement Register.

Complaint manager

  • Manage the complaint in accordance with this policy and the Complaints Management Procedure.

Quality Risk and Compliance team

  • Ensure complaints trend reports are provided in accordance with this policy and the Complaints Management Procedure.

13. Relevant Legislation, Policies, Procedures and Other Documents

13.1  Legislation

  • Aged Care Act 1997 (Cth) and User Rights Principles 2014 [Cth] (made under section 96‑1 of the Aged Care Act 1997)
  • Disability Discrimination Act 1992 (Cth)
  • Education and Early Childhood Services (Registration and Standards) Act 2011 (SA)
  • Health and Community Services Complaints Act 2004 (SA)
  • National Disability Insurance Scheme (Complaints Management and Resolution) Rules 2018 (Cth)
  • National Disability Insurance Scheme (Provider Registration and Practice Standards) Rules 2018 (Cth)
  • National Disability Insurance Scheme Terms of Business for Registered Providers 2016 (Cth)

13.2 Policies and Procedures

  • Complaints Management Procedure
  • Quality Management Policy

13.3 Other Documents (internal and external)

  • Stakeholder Feedback Register
  • Feedback Form
  • ‘Tell us what you think’ brochure
  • Continuous Improvement Register
  • Quality Management Schedule
  • Australian Service Excellence Standards
  • Home Care Common Standards
  • National Disability Insurance Scheme Practice Standards
  • National Standards for Mental Health Services
  • AS/NZS 10002: 2014 Australian/New Zealand Standard™ Guidelines for complaint management in organisations

14. Document History

Version No.Version DateNext Review DateApproved bySummary of Changes
3.022/1/1922/1/22EM Corporate ServicesMinor review:

7.2 – Internal Review added to meet requirement of Australian Service Excellence Standards

Responsibilities updated

2.016/10/1816/10/21EM Corporate Services3 Scope expanded to include representatives of consumers

5 Policy Principles updated to include requirement to refer and notify

6 Accessibility of Complaint Process amended to include more specific information about how information on complaints process is provided

7.1 Rights amended for contact within 2 business days rather than 5 to be consistent with the Complaints Management Procedure

8 National Disability Insurance Scheme (NDIS) Complainants added for compliance with NDIS (Complaints Management and Resolution) Rules 2018

Requirement for retention of records added to10 Recording Monitoring and Reporting to comply with NDIS Terms of Business

11 Training added for compliance with the NDIS (Complaints Management and Resolution) Rules 2018

12 Complaints System Review added for compliance with the NDIS (Complaints Management and Resolution) Rules 2018

Legislative references updated and references to relevant quality standards added

1.026/2/1826/2/21BoardDocument created

Separates Complaint Management Policy from Quality Management Policy.  Supported by Complaint Management Procedure.