Policy and Procedure: Feedback and Complaints

Purpose and Scope

The purpose of this policy and procedure is to set out how any person can provide feedback and make complaints about any aspect of Johnny H’s operations and the process that Johnny H will take to address or respond to feedback and complaints. It applies to all stakeholders of the business, including participants, families, carers, advocates, staff, other service providers, government agencies, and members of the community. It meets relevant legislation, regulations, and Standards as per Schedule 1.0 Legislative References. Feedback and complaints raised by Johnny H staff will generally be dealt with under Johnny H’s Disputes and Grievances Policy and Procedure, however from time to time, staff may raise issues or provide feedback that is best dealt with under this policy and procedure. Johnny H also has obligations in relation to incident management systems and reportable incidents that may apply to a complaint. See Johnny H’s Incident Management policies and procedures. Failure to comply with the complaints management requirements of the NDIS legislation and rules may lead to the NDIS Commissioner taking compliance and enforcement action against Johnny H.

Applicable NDIS Practice Standards

  • Feedback and Complaints Management
Definitions

Compliment: An expression of praise, encouragement, or gratitude about an individual staff member, a team, or a service. Complainant: A person who makes a complaint or has a complaint made on their behalf. Complaint: An expression of dissatisfaction made to or about an organisation, related to its products, services, staff, or the handling of a complaint, where a response or resolution is explicitly or implicitly expected. Feedback: A person’s thoughts, reactions, or feelings in relation to a service or product received that is often used as a basis for improvement. Procedural Fairness: A principle that requires a fair and proper procedure be used when making a decision.

Policy

Johnny H respects each person’s right to feel safe and comfortable to provide feedback or make complaints about the organisation or its services. Feedback and complaints are taken seriously as they provide Johnny H with valuable information about participants’ and others’ satisfaction and an opportunity to improve upon all aspects of service delivery. Johnny H’s complaints management and resolution system ensures people can easily make a complaint and have it dealt with fairly and quickly. Johnny H makes information available to participants and other stakeholders about how to make a complaint to it, the NDIS Commission, and any other relevant body, and keeps adequate records about complaints received. Johnny H prioritises the safety and wellbeing of children and young people and recognises the role of families and communities in helping them to understand and use this policy and procedure.

Procedures

General  Johnny H’s Leadership Team must promote best practice, continuous improvement, and an open, respectful culture that encourages and supports staff, participants, and other stakeholders to make complaints without fear of retribution. It reviews its effectiveness regularly, as per the Governance Policy and Procedure. As per Johnny H’s Human Resources Policy and Procedure, all staff must undergo Induction, which includes training in Johnny H’s feedback and complaints processes. Training must also help staff to:
  • Recognise and respond to neglect, grooming, and other forms of harm to children.
  • Understand the different ways children and young people express concerns or distress and disclose harm.
  • Provide appropriate support to children and young people in these instances.
  • Meet their legal requirements with respect to child protection.
  • Respond to different types of incidents and complaints involving children.
  • Understand their privacy obligations.
  • Develop their listening skills.
  • Feel confident drawing attention to breaches of Johnny H’s Code of Conduct and challenging these behaviours.
  • Understand how to respond to disclosures of harm and their reporting obligations.
Staff knowledge and application of this policy and procedure, and Johnny H’s feedback and complaints processes, as well as their obligation to protect children from harm, are monitored on a day-to-day basis and through annual Performance Reviews. Additional formal and on-the-job training is provided where required. Meeting Agendas for team meetings include a standing item on Continuous Improvement, including a review of feedback and complaints. Johnny H uses its Participant Handbook and Feedback and Complaints Form to provide participants, families, carers, and all other stakeholders with information about this policy and procedure, in an easy-to-understand format. Information provided includes how to make a complaint to Johnny H and to the NDIS Commission and other external bodies, how complaints will be addressed, and external advocacy and support services that can assist people in the complaints process.

Privacy and Information Management

All personal information Johnny H collects to manage feedback or complaints must be handled in accordance with Johnny H’s Privacy and Confidentiality Policy and Procedure. Staff must keep information about complaints confidential. They may only disclose necessary details if they are required to do so by law, or if not disclosing is likely to place the safety, health, or wellbeing of any person at risk. Staff must take all reasonable steps to notify the complainant before deciding not to keep personal information confidential. Johnny H’s Complaints Register must be used to record information about feedback and complaints, any action taken to resolve complaints, and the outcome of any action taken. All information regarding feedback and complaints is kept securely in accordance with Johnny H’s Records and Information Management Policy and Procedure. All records regarding complaints must be retained for at least seven years from the date they are created.

Feedback

Providing feedback to Johnny H is voluntary. Feedback can be provided at any time, in any way, by any stakeholder, through:
  • A staff member.
  • Email, mail, or phone.
  • Johnny H’s Feedback Form.
  • Staff collection of feedback after a person interacts with the service (e.g., initial assessment and planning reviews, exit interviews, etc.).
  • Annual participant satisfaction surveys. All participants or their representatives or families will be asked to complete these surveys.
  • Annual staff and stakeholder satisfaction surveys. All staff will be asked to complete these surveys, and stakeholders will be selected on a random basis.
Where feedback is provided verbally, the receiving staff member will transcribe it onto a Johnny H Feedback and Complaints Form.

Complaints

People can make a complaint about any aspects of Johnny H’s services, including breaches of its policies and procedures, Staff Code of Conduct, or the NDIS Code of Conduct. Johnny H’s complaints management process can be simplified into five steps:
  1. Complaint Lodgement To lodge a complaint, people are encouraged to speak directly to a staff member first, in an attempt to resolve the matter without recourse to Johnny H’s complaints procedures.Staff must:
    • Listen openly to the concerns being raised by the complainant.
    • Ask the complainant what outcome they are seeking.
    • Inform the complainant of the complaint process and how to formally make a complaint to Johnny H, the NDIS Commissioner, or other complaints bodies, as well as the expected timeframes for resolution.
    • Be empathetic toward the person and action all commitments made.
    • Act on situations that pose an immediate threat or danger or require a specialised response.
    If the complaint is resolved, it must be reported to the General Manager for inclusion in Johnny H’s Complaints Register. If the complaint cannot be resolved promptly or within 24 hours, it must be referred to the General Manager. The General Manager will advise the person of their right to lodge a formal complaint if they have not already done so, with the assistance of a support person or advocate if they wish. A Feedback and Complaints Form will be made available to the individual to lodge their complaint, although it is not mandatory to use the form. Formal complaints can be lodged:
    • Directly with a staff member, either verbally or by providing a completed Feedback Form.
    • By email to: ask.us@johnnyh.com.au.
    • By phone on 1300 053 001.
    • In writing to:
      • Queensland Offices: Shop 9/228 Varsity Parade, Varsity Lakes QLD 4227, and 2/210 Northward Street, Upper Coomera QLD 4209.
      • New South Wales Office: Unit 2/92-94 Batt Street, Jamisontown NSW 2750.
      • ACT Office: Unit 5/151 Newcastle St, Fyshwick ACT 2609.
    Anonymous complaints can also be made. Complaints and feedback can be lodged by a third party on behalf of another person, provided consent has been given by the individual or their legal representative. At any time, people can make a complaint about NDIS service providers or the support they provide to the NDIS Commission or other external complaints bodies (listed in the document). Staff must assist people making a complaint, or people with disabilities affected by a complaint, to contact the NDIS Commission or other complaints bodies when required. If a complaint alleges actual or possible criminal activity, abuse, or neglect, it must be referred to the General Manager immediately. The General Manager must report and action the complaint as per Johnny H’s Incident Management policies and procedures. Staff must take all reasonable steps to ensure complainants or people with disabilities affected by complaints are not adversely affected or fear retribution because a complaint has been made by them or on their behalf. Complaints made to Johnny H, the NDIS Commission, and other complaints bodies can be withdrawn at any time.
Complaints Under the National Code of Conduct for Healthcare Workers
Complaints can be made about healthcare practitioners under the National Code of Conduct for Healthcare Workers (Code of Conduct). The Code of Conduct sets out a range of minimum standards for health practitioners who:
  • are not registered under the National Registration Accreditation Scheme (NRAS). The NRAS covers 16 professions who are regulated by 15 National Boards, and is administered by the AHPRA (the Australian Health Practitioner Regulation Agency)
  • provide services unrelated to their registration or
  • are student or volunteer healthcare workers.
The types of practitioners the Code of Conduct applies to can include (but is not limited to) counsellors, dieticians, massage therapists, nutritionists, psychotherapists, social workers, and speech pathologists. It may also include some other types of allied, alternative, and community health service workers. The Code of Conduct requires healthcare workers to:
  • provide services in a safe and ethical manner
  • not provide healthcare of a type outside of their experience or training or services they are not qualified to provide
  • not make claims to cure certain illnesses
  • not financially exploit clients
  • not engage in improper personal relationships with a client
  • be covered by appropriate professional indemnity insurance and
  • display the Code of Conduct, and information about how to make a complaint.
Where the Code of Conduct applies to Johnny H staff, the People and Program Manager must advise those staff of their obligation to comply with it. Johnny H must also display the Code of Conduct in its premises, and ensure clients can access a copy, along with information about how they can make a complaint under it.
External Complaints Bodies

Outside Johnny H, complaints can be made to the following bodies. Staff must support people to make a complaint to these bodies, where this is required.

NDIS Quality and Safeguards Commission At any time, people can make a complaint about NDIS service providers or the support they provide to the NDIS Commission by: Phone: 1800 035 544. Phone hours services are currently available Monday to Friday (excluding public holidays) between 9am – 5pm for all States and Territories (except for the Northern Territory, available until 4:30pm). Online: https://www.ndiscommission.gov.au/contact-us/makeacomplaint
Australian Human Rights Commission Complaints regarding discrimination and breaches of human rights can be lodged with the Australian Human Rights Commission by: Australian Competition Consumer Commission (ACCC) Participants can contact the ACCC regarding obtaining information about consumer rights and can investigate complaints about breaches of these rights by: Participants also have rights under the Australian Consumer Law (ACL), including provisions on customer guarantees and unfair contract terms. Information and advice about customer disputes under the ACL are managed by individual State and Territory agencies. Contact details are provided below: ACT Office of Fair Trading (within Access Canberra) Office of Fair Trading Queensland NSW Fair Trading Australian Securities and Investments Commission (ASIC) Participants can contact ASIC if they have concerns regarding consumer protection in relation to finances via the ASIC website at: https://asic.gov.au/for-consumers/how-to-complain/ Additional External Complaints Bodies The ACT Human Rights Commission The ACT Human Rights Commission (HRC) can deal with complaints about abuse, neglect, or exploitation of vulnerable people. Complaints can be lodged by: For the purpose of the HRC complaints function, a vulnerable person is:
  • A person older than 60 who has a disability or impairment or for some reason is socially isolated or unable to participate in community life; or
  • Any adult with a disability (defined in the Disability Services Act 1991) which includes an intellectual, physical, sensory, or psychiatric impairment.
Queensland Ombudsman The Queensland Ombudsman investigates complaints relating to Queensland Government departments and agencies. Complaints can be lodged by: Queensland Human Rights Commission The Queensland Human Rights Commission deals with complaints relating to human rights and discrimination. Complaints can be lodged by: New South Wales Ombudsman The NSW Ombudsman investigates complaints about New South Wales Government agencies and certain non-government organisations. Complaints can be lodged by: Anti-Discrimination Board of NSW The Anti-Discrimination Board of NSW investigates complaints relating to breaches of the Anti-Discrimination Act 1977 (NSW). Complaints can be lodged by: Complaints to the Commonwealth Ombudsman about the NDIA can be lodged: Staff must support participants making a complaint about the NDIA to contact the Agency or Commonwealth Ombudsman, where this is required. 2. Record The General Manager must record all information relevant to complaints, in its original and simplest form, in Johnny H’s Complaints Register. The Complaints Register must be stored in a secure file, accessible only to the Leadership Team. Other staff may access the Complaints Register only if it is relevant and appropriate to the nature of their role and with permission from the Leadership Team. 3. Acknowledge The General Manager must acknowledge receipt of complaints within 2 working days. However, where a person has requested to remain anonymous, contact may not be possible or expected. In their acknowledgement, the General Manager must set realistic expectations regarding complaint resolution and refer the matter to other organisations where they are identified as being more suitable to handle it. Acknowledgements must provide timeframes for resolution where possible. 4. Resolve Investigation of a complaint must not be conducted by a person about whom the complaint has been made, or a person who has a conflict of interest in the matter. If required, the Leadership Team will determine the appropriate person to undertake the investigation. In resolving a complaint, the General Manager must involve the complainant and keep them informed of the progress of the complaint. They must discuss any disparities identified with the complainant and may request additional information when required. A timeframe within which further information is to be provided should be clearly communicated with the complainant. The General Manager should consider granting extensions where necessary and always communicate any additional time requirements to the complainant with an explanation of the need. Complaint investigation must focus on the identified complaint matters only. All parties involved in a complaint must be provided with procedural fairness and with the support and information necessary to participate in the complaints process. All decisions or actions regarding complaint investigation must be recorded by the General Manager in Johnny H’s Complaints Register. 5. Communicate Resolution Johnny H will respond to all complaints as soon as possible and within 5 working days from acknowledgment. If a complaint cannot be responded to in full within 5 working days of acknowledgment, an update must be issued to the complainant. The update must provide the date by which a full response can be expected. The update should be provided verbally in the first instance, then confirmed in writing. The General Manager should discuss the outcome of a complaint investigation verbally with the complainant, where possible. This must be followed by written advice that provides the complainant with an opportunity to make further contact with the General Manager if required. The written advice must also include information on what further action may be available to the complainant at the conclusion of the complaint investigation. This may include escalating the matter further with an external agency or seeking a further review within the business. Written advice should also seek feedback from the complainant regarding their experience of the complaints process. Support must be provided to assist complainants’ understanding of correspondence regarding complaints, where this is required (e.g., interpreters, referral to advocates, etc.). Options for responding to a complaint may include, but are not limited to:
  • Explaining processes.
  • Rectifying an issue.
  • Providing an apology.
  • Ongoing monitoring.
  • Training or educating staff.
Once resolved, complaint outcomes must be relayed to the appropriate area within Johnny H in order to improve service delivery.

Feedback and Complaint Review

Feedback and complaint review includes identifying, monitoring, and acting upon trends and systemic issues identified through the analysis of feedback and complaint information. The purpose of analysing feedback and complaint data is to learn from patterns, to safeguard the safety and wellbeing of individual participants, as well as to improve the quality of supports. The Complaints Register must be reviewed at weekly Leadership Team meetings. The General Manager is responsible for monitoring the Complaints Register in order to analyse and report on trends. Reviews should consider:
  • The causes, handling, and outcomes of feedback and complaints.
  • Processes, timeframes, and record-keeping practices associated with feedback and complaint management.
  • Feedback provided by staff and participants about Johnny H’s feedback and complaint management.
Where preventative or improvement measures are identified, these must be tracked in the Continuous Improvement Plan. Practice Reviews Depending on the nature of any feedback and complaints received by Johnny H (including trends or an absence of complaints), a practice review may be required. See Johnny H’s Continuous Improvement Policy and Procedure for more information on when a practice review is required and how to conduct practice reviews. Supporting Documents Documents relevant to this policy and procedure include:
  • Governance Policy and Procedure
  • Privacy and Confidentiality Policy and Procedure
  • Records and Information Management Policy and Procedure
  • Disputes and Grievances Policy and Procedure
  • Workplace Incident Management Policy and Procedure
  • Participant Incident Management Policy and Procedure
  • Human Resources Policy and Procedure
  • Continuous Improvement Policy and Procedure
  • Meeting Agendas
  • Feedback and Complaints Form
  • Complaints Register
  • Participant Charter
  • Participant Handbook
References

Monitoring and Review

This Policy and Procedure will be reviewed at least annually by the Leadership Team. Reviews will incorporate staff, participant, and other stakeholder feedback. Johnny H’s feedback collection mechanisms will assess:
  • Satisfaction with Johnny H’s feedback and complaints processes.
  • Whether stakeholders have received adequate information about making complaints and their awareness of complaints mechanisms.
  • The extent to which participants and their supporters feel they have been included in the review of feedback and their satisfaction with this process.
  • Whether stakeholders have received adequate information about how the organisation will use feedback, complaints, and appeals information.
  • Any barriers to lodging complaints and feedback.
Johnny H’s Continuous Improvement Plan will be used to record improvements identified and monitor the progress of their implementation. Where relevant, this information will be considered as part of Johnny H’s service planning and delivery processes.

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