QHC COMPLAINTS MANAGEMENT POLICY
 
PURPOSE
The policy informs all Quality Health Care (QHC) staff of the client’s right to complain and the mechanisms in place to listen to and address raised concerns.  The policy outlines required preventative and responsive actions in relation to client dissatisfaction and complaint.  The policy outlines QHC’s systematic approach when dealing with complaints in which analysis of quality of care and service of each individual or complaint source. 
 
DEFINITIONS
ADVOCACY
'standing by' someone, or 'speaking out' for someone's rights, or 'going in to bat' for another person - being 'on their side', especially when the chips are down."(in Parsons 1. 1994. Villamanta Publishing)
 
A complaint is:
• an expression of dissatisfaction with a service offered or provided, or
• a concern that provides feedback regarding some aspect of the service that identifies issues requiring a response.
A good way to determine whether an expression of dissatisfaction is a complaint or not is to ask: “What is being sought and what is needed to resolve this matter?” If some action or response is identified, a complaint is to be dealt with.
A complaint may be made in regard to policies, procedures, employee conduct, provision of information, quality of communication or treatment, quality of a service, or access to and promptness of a service.  Complaints do not include requests for services or information, explanations of policies and procedures, or industrial matters between the service and unions.[1]
 
Resolution is the desired outcome of a complaint. It is a responsive process that seeks to address a person’s concerns and accompanying emotions.
Resolution, on a continuum, can range from informal “on the spot” discussions to more structured and planned resolution negotiations and meetings. A resolution is not only an outcome but a temporary relationship between the parties involved. It is a process whereby complaints are heard, assessed, negotiated, responded to, and resolved.
 
TARGET GROUP
All Clients, family members and carers, stakeholders and staff of QHC.
 

 
POLICY STATEMENT
QHC complaints management aims to restore the trust and support a client receives from the service, to identify any emerging patterns of practice, to highlight any system or process deficiencies, to address any individual performance matters and to provide critical clinical information for risk management and quality improvement. 
 
In QHC complaints management is each staff member’s responsibility and part of effective communication.  Complainants are to be treated with dignity. They are assured that their complaint is taken seriously. They have the right to an independent advocate.  A positive attitude by QHC staff is crucial to the success of the complaint management process.
 
QHC accepts any feedback in relation to the delivery of services.  Complaints can be received in verbal or written form with any situation that cannot be immediately resolved registered on the QHC complaints data-base.  Complaints are resolved with observable and measurable change for the client; with the actions made in consultation with the client and their circle of support.  This is fed back in a format that is reflective of the person’s individual and cultural needs.
 
QHC is committed to promoting the rights of clients and to ensuring that it acts fairly for all parties involved in the complaint resolution process. 
 
QHC follows required actions when alleged illegal actions are reported with referral to the relevant legal body. 
 
POLICY PRINCIPLES
 
  • Clients are informed of their right to complain and supported to provide continuous feedback to Quality Health Care about any concerns.
 
 
  • QHC has a systematic method of maintaining information to ensure risks associated with delivery of care are recorded, analyzed and responded to effectively.
 
 
  • If staff at the point-of-service can resolve complaints at first contact, escalation can be avoided and complaints can be resolved directly and quickly to the satisfaction of all parties.
 
 
  • All clients have the right to access an independent advocate, in particular those clients who do not have access to a personal network and who need assistance to speak up. 
     
  • QHC staff actively offer clients access to an independent advocate and promote clients’ right to an advocate of their choice.
 
 
  • QHC respond positively to independent advocacy on behalf of clients.
 
 
  • QHC provides information about complaints and dispute resolution in formats that clients can understand.  See QHC Complaint brochure.
 
 
  • In the event that the complaint is of a criminal nature (allegation of theft, abuse) a referral to the Police or relevant authority is made and the matter monitored by a Director.
 
 
  • Complaints can be an indication that there is a gap in service delivery, which indicate a difference between service delivery expectation and perception, and the service provided.  Complaints are not interpreted by management or staff as a representation of incompetence or inefficiency; complaints are not centered on any one individual, but rather the process of service delivery that needs to be reviewed.
 
 
  • QHC Complaints handling policy and procedure information is provided to all new employees.  Staff are offered communication skill development opportunities to assist in the prevention of complaints.
 
Responsibilities
Directors are responsible for providing a robust complaints process and recording system.  Directors respond to complaints addressed to them and review all registered complaints and ensure that each complaint is assessed and appropriate actions taken to minimise any potential risks.
 
Managers and Coordinators are responsible for entering any significant risks on the Incident and Non Conformance Record; responding to complainant in a timely manner; assessing any actions taken or required (including facilitating access to an independent advocate); monitoring implementation until resolution is reached; and contacting the referring agent to discuss the complaint.
 
All staff are responsible for responding professionally to all feedback received and to record any significant complaints made by clients, their family or stakeholders. 
 
Procedures
All staff are responsible for maintaining records in relation to the services they provide.  Additional reports such as incident reports, hazard reports or client review forms are completed when indicated. 
 
All staff are encouraged to maintain positive working relationships and communication with clients as this underpins quality service delivery.  Clients have an expectation of service and outcomes of care, therefore addressing clients’ concerns at the point of service delivery assists with preventing complaints.  A client may require contact and clarification in order that their concerns are resolved and do not become a complaint.
 
Staff are to make referral to advocacy service on behalf of clients who do not have access to a personal network and need assistance to have their personal situation heard.
 
In situations when a client or advocate makes a complaint, staff are to listen and document without question the matters relating to the complaint.  If the matter cannot be resolved immediately or through an agreed plan with the client, then staff are to complete an Incident or Non Compliance form.
 
Staff are to offer an opportunity to the client or advocate to write down their complaint or to contact the Director to raise their complaint. 
 
All complaints are provided to the Manager to begin the process of complaint resolution in consultation with the Referring Agent or client’s Case Manager.  The Manager communicates with the Referring Agent within 24 hours of receiving a complaint.
 
As appropriate, the Manager arranges a complaints resolution meeting to clarify what the complaint is, clarify any expectations relating to the service provided by QHC, and establish actions that will achieve a resolution to the compliant.  An action plan is developed and resolution is achieved when all actions are satisfactorily completed.
 
Following Complaint Resolution Meeting minutes an action plan is provided to all parties.  A letter of Resolution is provided to all parties once the complaint is resolved.
 
In the event that a complaint is received within a Client Survey, the complaint is referred to the Manager to request information from all stakeholders of the complaint, assess the information and begin any relevant actions.  When indicated, to organize a resolution meeting and respond with a letter when the complaint is resolved.
 
The Committee of Management undertakes evaluation of complaints within the quality review process to inform delivery of appropriate and continually improving service delivery.  Service delivery improvement strategies are identified within this process and implemented.
 
Clients are provided with information to assist them with making a complaint, including the appropriate external complaint support body such as the NSW Health Care Complaints Commission and the NSW Ombudsman Disability Complaints Unit. 
 
 
Reference TO guidelines and relevant forms
Information within this policy includes ‘Customer Complaints Policy’ document provided by eqstats http://eqstats.com.au/
 
NSW Ombudsman Fact Sheet - Community Services Division fact sheet No 2.
 
QHC How to complain leaflet.
 
Links, LEGISLATION and reference documents (including links to standards)
 
NSW Health Care Complaints Commission
Complaints to the Commission must be in writing and you can contact the Commission's Inquiry Service on (02) 9219 7444 or Toll Free on 1800 043 159 to discuss your concerns.
 
NSW Ombudsman http://www.ombo.nsw.gov.au/disability.html
NSW Ombudsman’s office handles complaints about a range of disability services including
 
  • Residential services, respite care, community access,
  • Community support programs
  • Day, activity and recreation programs
  • Home care and
  • HACC services
 
Contact number (02)9286 1000 or toll free from outside Sydney on 1800 451 524.
 
Ombudsman Act 1974 (including Part 3A related to child protection).
 
Community Service Complaints, Reviews and Monitoring Act 1993 No 2.
 
Disability Inclusion Act, 2014
 
Disability Inclusion Regulation, 2014
 
Privacy and Personal Information Act, 1998
 
National Disability Insurance Scheme (NSW Enabling) Act, 2013
 
Government Information (Public Access) (Consequential Amendment and Repeal) Act 2009 No 54Interpretation Act 1987 No 15
 
Disability Services Act 1993 No. 3
 
Disability Service Standards:
 
  • Standard 1. Rights
  • Standard 2. Participation and Inclusion
  • Standard 4. Feedback and Complaints
  • Standard 6. Service Management
 
[1] Complaint Management Guideline, Department of Health publication GL2006_023 date 20/12/2006