Client Feedback and Complaints policy

This policy applies to all feedback and complaints from customers, families, carers, advocates, statutory bodies, government agencies, stakeholders, employees or members of the public to or about the Yooralla Board, Executive employees, non-Executive employees, volunteers and contractors.

Exclusions: any work-related grievance, which is subject to Human Resources policies and procedures.

This policy should be read in conjunction with Yooralla’s Risk Management Policy and Quality Into Practice Framework.

This policy outlines Yooralla’s approach to receiving customer feedback in managing and responding to complaints including how to:

• respond to and manage all feedback and complaints in a consistent, fair, transparent and timely manner;
• improve the services that Yooralla provides and the way in which they are provided;
• improve practice and how it can be more responsive to customer support needs;
• learn from and use feedback and complaints to inform planning, policy development and resource allocation;
• focus on positive person-centred solutions;
• conduct ourselves in line with Yooralla’s corporate values;
• respect choices; and
• learn and introduce changes arising from feedback.

Yooralla values all feedback from various stakeholders such as customers and their families or their support networks, employees, statutory bodies, government agencies, other service providers and members of the public.

Yooralla promotes people’s right to speak up and is committed to ensuring that people feel sufficiently confident to express any concerns. Yooralla is committed to ensuring that all feedback and complaints are acknowledged within a 3-working day time frame and resolution of complaints is addressed within a 21-working day time frame. There may be instances where external dispute resolution parties are involved such that outcomes are outside of Yooralla’s control.

All Yooralla employees are required to:

• ensure that people understand their rights in relation to feedback and complaints, and their right to contact the NDIS Quality and Safeguards Commission directly or contact an independent support person or advocate if they choose to do so.
• make Yooralla’s feedback and complaints processes accessible including providing the complainants with appropriate support to enable them to make the complaint including the ability to raise concerns about the specialist disability accommodation dwelling or supported independent living arrangements.

The support includes, for example, people with a vision-impairment receiving their complaint statement by audio format, supporting the complainant to make the complaint/feedback in a language other than English, supporting the complainant to choose a reasonable mechanism and/or venue for making their complaint statement

• focus on positive solutions for the customer and consider and share ideas where improvements could be applied more broadly;
• respect the independence, control and choices of the customer;
• ensure best endeavours are made such that satisfactory resolution of complaints can be achieved;
• promote the benefits of feedback and complaints to customers and employees;
• be guided by person centred approaches and collaborate with the customer and families/carers or support network to achieve a resolution;
• promote a culture where complaints are seen as opportunities for improvement;
• support people who use Yooralla services to provide feedback;
• maintain confidentiality of information about the complaint and the person who made it;
• safeguard people against retribution or unfavourable treatment if they make a complaint; and
• meet the Yooralla reporting and review obligations.

Yooralla’s feedback and complaints process ensures:

• Privacy: reasonable steps are taken to protect personal information from loss, unauthorised access or use, unauthorised disclosure or any misuse during the complaints process.
• Confidentiality: information is protected with controls on how and when certain information is used within the organisation and/or disclosed to an outside agency or person.
• Natural justice:
• Yooralla provides all people with a fair hearing when looking into and making decisions about complaints;
• Yooralla responds to complaints with impartiality and without bias;
• Yooralla lets people know about any improvements made as a result of a feedback and complaint; and
• any customer likely to be affected by a decision made in response to a complaint is given relevant information.
• Employee awareness of Yooralla’s Customer Feedback and Complaints Policy and Customer Feedback and Complaints Procedure.
• Timeliness in dealing with complaints appropriately and effectively, within the specified time frames.

All employees who have contact with customers should:

• know and be trained in complaints handling based on the Understanding Complaints training in the NDIS Commission Complaints Management and Resolution Guidelines;
• comply with any complaints-handling reporting requirements that includes entering the feedback in Riskman. If the complaint refers to a specific event enter this as an incident as well as a complaint;
• treat customers and stakeholders in a courteous manner and respond promptly to feedback and complaints;
• show positive customer-focussed interpersonal and communication skills;
• be aware of their roles, responsibilities and authorities in respect of feedback and complaints;
• be aware of what procedures to follow and what information to give to a person who makes a complaint;
• act promptly on feedback and complaints that can be resolved immediately at the local level;
• proactively collaborate with the customer and families/carers or support network to resolve feedback and complaints; and
• refer the feedback and complaint to the line manager if the matter needs further mediation or requires dispute resolution.

Managers

Managers involved in the complaints-handling process are, as applicable within their area of responsibility, responsible for:

• ensuring that the complaints-handling process is implemented and that employees are trained in complaints handling;
• liaising with the Customer Relations and Empowerment Officer for advice and assistance on matters that are at the level of the NDIS Commission or Disability Services Commissioner for resolution;
• promoting a positive culture of seeking and acting promptly on feedback and complaints, and actively engaging customers and their families/carer or support network in the resolution process and recording their satisfaction with the resolution in RiskMan;
• ensuring that information about the complaints-handling process is easily accessible to customers and their families/carers;
• ensuring timely compliance with relevant legislative and statutory requirements, such as responding to the NDIS Commission, Disability Services Commissioner, Community Visitors, the Public Advocate and relevant government agencies;
• informing and referring the customer and/or family member/carer to an independent advocate or support person if they so choose and to obtain consent for the referral. An independent advocate or support person may come from Yooralla’s Customer Rights and Empowerment Team, a registered external advocacy organisation, and relevant statutory bodies or government departments;
• reporting upon actions and decisions with respect to feedback and complaints to customers and their families, and to the respective line manager;
• ensuring monitoring of the complaints-handling process and that actions are implemented as evidenced in an action plan or register;
• reflecting upon and implementing improvements in response to specific themes that are identified from the feedback process;
• ensuring that complaints-handling data are available for Executive management review;
• ensuring that there is a process for rapid and effective notification to Executive management of any complaints requiring an organisational response or of a serious nature that requires prompt action by the Executive;
• proactively engaging with customers and key stakeholders (such as internal or external groups, government agencies and statutory bodies) to prevent and address issues before they escalate into a complaint;
• ensuring that a different person completes the resolution process with the customer who is independent of the previous proceedings; and
• complying with the NDIS Complaints Management and Resolution Rules 2018.

The Chief Practitioner and his/her team are responsible for:

• establishing a process of performance monitoring, evaluation and reporting to identify themes and systemic issues;
• advising senior management of the customer’s right to an independent advocate or support person, and that in some matters such a referral may be beneficial for the customer and family member/carer;
• providing regular reporting to Yooralla Executive and senior management, the Board and its Service Delivery and Quality Committee, and relevant stakeholder advisory groups regarding Yooralla’s compliance with organisational key performance indicators relating to feedback and complaints;
• providing regular analysis of feedback and complaints, and identifying potential organisational learning opportunities to the Chief Executive Officer (CEO) and Executive;
  
• undertaking and reporting an annual analysis of feedback and complaints to the CEO and Executive, Board and Service Delivery and Quality Committee, and relevant internal stakeholder groups where appropriate for the purposes of organisational learning and developing appropriate strategies in partnerships with relevant internal or external stakeholders;
• maintaining a feedback and complaints register and monitoring that agreed actions arising from feedback and complaints have been actioned and completed, and bringing matters to the respective Executive Directors/Chiefs for further action if required;
• maintaining the effective and efficient operation of the feedback and complaints handling process; and
• supporting and working with senior management and the Executive to respond to feedback and complaints, particularly in relation to the NDIS Commission, Disability Services Commissioner, Public Advocate, Community Visitors and government agencies.

Executive management is responsible for:

• ensuring that the complaints-handling process and objectives are established;
• ensuring that the complaints-handling process is planned, designed, implemented, maintained and continually improved in accordance with legislative and government requirements;
• identifying and allocating the management resources needed for an effective and efficient complaints handling process;
• promoting awareness of the complaints-handling process and the need for a customer-focussed approach throughout the organisation
• ensuring senior management’s responses are timely and customer-focussed, and comply with relevant legislative and government requirements;
• communicating to the Board and its Service Delivery and Quality Committee on feedback and complaints, and their resolution(s) that require Board-level attention
• appointing or delegating a representative to coordinate the management of a serious complaint and clearly defining their responsibilities and authority
• periodically reviewing the complaints-handling process to ensure that it is maintained effectively and efficiently, and improved continually; and
• using the evidence based on feedback and complaints in strategic planning, service design and policy development.

Chief Executive Officer

Is responsible for responding to or managing any broader approaches such as:

• promoting a customer-focussed approach to feedback and complaints
• initiating responses to media enquiries
• ensuring that appropriate engagement exists with external complaints handling bodies such as the NDIS Commission or the Office of the Disability Services Commissioner
• ensuring that there are mechanisms to respond to complaint matters raised by key funders of services; and
• liaison with government departments or statutory bodies in relation to feedback, complaints or allegations of abuse, harm or neglect.

• Complaints Handling

• Annual Complaints Reporting tool – Office of the Disability Services Commissioner (ODSC)
• Complaint Form – Office of the Disability Services Commissioner (ODSC)
• Compliments and Complaints Management Policy – DHS
• Client Charter of Rights and Responsibilities
• Customer Feedback and Complaints Procedure Manual
• Good practice guide and self-audit tool – Office of the Disability Services Commissioner (ODSC)
• Information Sheets – Office of the Disability Services Commissioner (ODSC)
• Management of Customer Incidents Policy
• NDIS – Feedback, and complaints
• Preventing and Responding to Abuse and Neglect – Statement of Intent
• Privacy Policy
• Publications and Resources – Office of the Disability Services Commissioner (ODSC)
• Quality Into Practice Framework
• TAC Complaints Flow Chart
• The Disability Services Commissioner’s values and principles
• Your Yooralla Experience – Feedback Poster
• Your Yooralla Experience –Form
• Yooralla’s Feedback and Complaints RiskMan Database

Appendices

• Appendix 1 – Yooralla Complaints Management Flowchart
• Appendix 2 – Managing difficult or abusive callers