CPS Choice Plan Services
Everyone (participants and their families, workers and other providers) at CPS Choice Plan Services is encouraged to provide feedback or make a complaint (including an anonymous complaint) through multiple mechanisms including conversations with the CPS Choice Plan Services Manager, phone calls, emails, websites and third parties.
In line with the focus on participant rights and person-centred care, CPS Choice Plan Services informs and encourages participants to provide feedback or make a complaint through the Service Agreement and conversations with their provider.
Information on how to make a complaint is provided to participants before services commence and reinforced during support delivery. The management of mistakes, complaints and incidents contribute to a process of reflection and continuous improvement. Open and honest feedback is a transparent way for persons with a disability, their carer’s, family or advocate of choice, to contribute to the process of complaint reporting, management and resolution.
The participants and their families are provided with the opportunity to provide feedback or make a complaint at the time of their reviews but also at any time during service delivery.
Workers are informed on this policy at time of induction and then annually.
All feedback, both positive and negative, is used by CPS Choice Plan Services to evaluate service effectiveness, and to make changes to ensure everyone is safe and satisfied. A review of the complaints management and resolution system will be conducted biannually by the Independent Review Committee (May & November).
Confidentiality – information provided in a complaint is kept confidential and only disclosed if required by law or if the disclosure is otherwise appropriate in the circumstances.
All complaints must be kept for 7 years from the day the record is made.
(Note: A registered NDIS provider may be required to comply with other Commonwealth, State, or Territory Laws in relation to the retention of records)
Complaints will be managed as per the National Disability Insurance Scheme (Complaints Management and Resolution) Rules 2018, NDIS Quality and Safeguards Commission: Complaints Management and Resolution Guidance, Version 2.1 – September 2019 and the NDIS Effective Complaint Handling Guidelines for NDIS Providers.
CPS Choice Plan Services is to ensure that participants and clients know how to make a complaint about service provision, and that they can also make complaints directly to the NDIS Commission, or to the local South West Advocacy Association.
CPS Choice Plan Services is to ensure that the involvement of the person making the complaint, and any person with a disability affected by issues raised in the complaint, are communicated with throughout the complaint management and resolution process in an appropriate way that meets their needs.
All feedback and complaints are documented and changes made, as required, to improve service delivery and procedures to improve participant satisfaction. CPS Choice Plan Services is to ensure that a participant or client is not disadvantaged from receiving supports and services if they make a complaint and that their service in the future will not be affected.
Complaint Is a statement that something is unsatisfactory.
NDIS Commission “A complaint is 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 or legally required.”
Feedback Information about reactions to a service, a person’s performance of a task, a product etc. which is used as a basis for improvement.
Feedback can be positive or negative.
Note: As per the definitions in the Incident Management Policy, a complaint or negative feedback about the service is also a type of incident.
- Incident Management Policy and Procedures
- Risk Management Policy and Procedures
- Risk Management Register
- Service Delivery Model
- Incident and Complaint Report form
- Incident Register
- Complaint Register
- Incident Investigation Form
- Human Resource Management Policy and Procedures
- NDIS Quality and Safeguards Commission: Complaints Management and Resolution Guidance, Version 2.1 – September 2019
- NDIS Effective Complaint Handling Guidelines for NDIS Providers – includes a valuable approach to managing complaints extracted from Victorian Disability Services Commissioner booklet ‘Everything you wanted to know about complaints…’, – refer to Appendix.
- Participants are provided with information on how and where to provide feedback / make a complaint before services commence through provision of information:
- In the NDIS Service Agreement
- On the website
- Participants have the opportunity to provide feedback / make a complaint at any time and more particularly at the time of reviews and participant surveys
- Participants can complain directly to the Contact the NDIS Quality and Safeguards Commission
- via phone 1800 035 544
- by filling in an online complaint form.
Management of a complaint will be handled as per any incident as follows.
|What will we do
|Who is responsible
|Stage 1 – Informed
|All participants and clients are to be provided with information on how to make a complaint (including an anonymous complaint) either to CPS direct or to a third party such as the NDIS Quality and Safeguards Commission.
|If a participant is making the complaint confirm if they wish to use an independent advocate to assist in making the complaint. This may be a family member, friend, trusted decision-maker or appropriate advocacy service. If / as required, assist the participant to access an advocate as required by referral to appropriate service such as:
|All employees are to be informed on how to make a complaint at their induction into CPS, then have refresher information on a regular 12 month cycle or when legislation requires a change to policy
Ongoing training plans
|Stage 2 – Investigation
|All complaints regardless of importance are to be acknowledged and documented in the Complaints/Feedback Register. First hand details are preferred unless a participant, member of the public or staff member requires assistance to complete the details.
|Within 24 hours of notification.
Complaints are to be disseminated to the Manager for resolution using the recommended approach of:
Where possible, the participant or client should be involved in the process to the best of their ability to acknowledge and value their input.
|Within 24 hrs. If the complaint involves significant investigation, whoever lodged the complaint is to be advised of an estimated time and informed what actions are being taken and who they should be in contact with at CPS. Actions and outcomes are to documented in the Complaints/Feedback register.
|All documentation such as emails and forms are to be made into a PDF and attached to relevant complaint in the Complaints/Feedback Register.
|Where a complaint involves a criminal matter, it will be referred to the Police. The person who made the complaint will be advised. All other relevant reporting jurisdictions are to be advised. In general, complaints should not be open longer than 10 working days.
|Procedural fairness must be observed when handling complaints to ensure that all persons involved in a complaint are treated fairly.
In collaboration with the complainant, decide on the course of action. The actions should include / address:
How to resolve the complaint. This could include acknowledgement, an apology, answers and / or action
Where appropriate, seeking feedback from others e.g. other clients / Participants, workers
When, how and through whom (e.g. advocate) complainant will be kept informed of progress
How to improve the service if / as required. This could include:
Further training of staff / others involved
Reviewing and enhancing policies and / or procedures
|Stage 3 – Escalation
|Where a person who has lodged the complaint is not satisfied with the process, actions or with the individual handling the complaint, they can request for the complaint to be escalated.
|If the complainant is still not satisfied with the way the complaint has been handled or the outcomes achieved, they can contact the NDIS Quality and Safeguards Commission, National Disability Neglect & Abuse Hotline
|Stage 4 – Resolution
|At the end of the investigative process and when an outcome is achieved, this must be documented and advised to the person making the complaint. This should be delivered in their preferred form of communication. EG – phone, followed by letter or email.
|Within 24 to 48 hours of final investigation if internal.
|Stage 5 – Appeal
|Procedural fairness allows the right to appeal a process that has delivered an outcome.
|An appeal can only address the process to be followed in reaching a decision, but not the substantive merits of the outcome. A person with a complaint outcome that they believe is unsatisfactory, will again be directed to the NDIS Quality and Safeguards Commission.
|Stage 6 – Closure and Opportunity
|Complaints can play an important role in strengthening and driving improvements in the quality of supports and services. Complaints can highlight weakness in service provision, unmet expectations and misunderstandings.
A review of the process should be conducted including what service, policy or procedure did it call into question.
Was the process positive and well communicated?
Can we identify and improve services, policies and procedures including training around the matter of the complaint?
The following is an extract from the NDIS Quality and Safeguards Commission’s Effective Complaint Handling Guidelines for NDIS Providers
In responding to a complaint, the Four A’s of successful resolution is a useful approach developed by the Victorian Disability Services Commissioner in their booklet ‘Everything you wanted to know about complaints…’:
The approach recognises that people who make a complaint are generally seeking one or more of these four outcomes:
In many ways this is the most important step as it sets the tone for the rest of the process. Making a complaint can be difficult for people. It is important that people feel that their concerns have been understood and that the impact on them is recognised.
Acknowledgment can include:
People want to know why something has or has not happened, or why a decision was made. People need to understand what has happened in order to better understand how they can move on to resolving their concern. Answers should include a clear explanation that is relevant to the concern raised but ONLY if you know the facts.
People want you to fix or take steps to address their concerns. This may be in relation to their specific complaint, or more broadly around systems to ensure that similar issues won’t occur for other people. Sometimes you won’t be able to fix the issue raised, but you can initiate actions to prevent it from happening again. Taking action to prevent recurrence may validate the concern for the person making the complaint. A good way to approach actions is to use an action plan, which includes:
The action plan may be formulated with the person who raised the complaint and any participant affected by an issue raised in the complaint. It is really important to follow up with the person who made the complaint, and any affected participant, to make sure they are satisfied with the actions being undertaken, and that the actions relate appropriately to their concerns. This is also a good opportunity to seek their feedback on the complaints resolution process.
An apology may be part of, or the sole outcome a person is seeking when they make a complaint. It is important to consider who should provide the apology and the form of the apology. A genuine apology can be a meaningful step; however a poorly provided apology can make the situation worse. An apology should often come from the person complained about, as well as a more senior member of the organisation, in order for the person complaining to be satisfied that their concerns were taken seriously.
When providing an apology, it is helpful to consider:
A genuine and timely apology is a powerful healing force and a way to separate the past from the future, to put things to rest and get on with any agreed new arrangements.
It is important that you have systems in place to allow the organisation to reflect on the complaints process and any outcomes. This includes ensuring that you are checking in with the person who made the complaint for feedback around the finalisation of their complaint, and their response to any follow up or implementation of actions.
Things to consider: