CPS Choice Plan Services

CPS Choice Plan Services

Feedback and Complaints Management Policy & Procedures

1.    Policy

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.

2.    Outcome

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.

3.    Definitions

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.”

NDIS Quality and Safeguards Commission: Complaints Management and Resolution Guidance, Version 2.1 – September 2019 p8 

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.

4.    Related Policies / Documents

Internal

  • 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

External

5.    Procedures

Making Participants Aware that Feedback, including Complaints, are Welcomed

  1. 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
  1. Participants have the opportunity to provide feedback / make a complaint at any time and more particularly at the time of reviews and participant surveys
  2. Participants can complain directly to the Contact the NDIS Quality and Safeguards Commission

Management of a Complaint

Management of a complaint will be handled as per any incident as follows.

What will we doWhenWho 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.

Intake

Service Agreement

CPS Manager
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:

Disability Advocacy Finder

www.southwestadvocacy.org.au

http://www.disabilityadvocacyvic.org.au/

CPS Manager
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

Induction

Ongoing training plans

CPS Manager
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.CPS Manager

Complaints are to be disseminated to the Manager for resolution using the recommended approach of:

·         Acknowledge

·         Answers

·         Action

·         Apology

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.CPS Manager
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.CPS Manager
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

CPS Manager
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 HotlineCPS Manager
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?

CPS Manager

6.    Appendix: How to respond to a 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:

  • Acknowledgment
  • Answers
  • Action
  • Apology

 Acknowledgement

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:

  • genuinely listening to the person without interrupting
  • empathising
  • making sure the person feels comfortable talking to you, and being aware of whether you are feeling defensive and how this may be perceived
  • acknowledging how the situation has affected the person
  • rectifying by asking the person what a good outcome would look like for them, and
  • notifying the person regularly and promptly of the steps that will be taken in response to their complaint, ensuring commitments aren’t made that can’t be fulfilled.

 Answers

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.

Actions

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:

  • what will be done
  • who will do it
  • when it will be done by
  • how the progress of the complaint and outcomes will be communicated to the person making the complaint and the participant, and
  • how the progress of the complaint actions and implementation will be oversighted.

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.

Apology

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:

  • timeliness
  • sincerity
  • being specific and to the point
  • accepting responsibility for what occurred and the impacts caused
  • explaining the circumstances and causes (without making excuses), and
  • summarising key actions agreed to as a result of the complaint.

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.

After a complaint has been dealt with

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:

  • What was the complaint about? What service, policy or procedure did it call into question?
  • What was the experience for the person who made the complaint, or for any affected participant? Were the issues resolved for them?
  • What information did the complaint provide that will allow you to identify and improve those services, policies and procedures and your organisation as a whole?
  • How effectively did you communicate with the person who made the complaint, any affected participants, affected staff and other stakeholders?
  • Do people using your services, their families, carers and friends require more or improved information about their rights and the complaints process? Does the person who made the complaint feel more comfortable about speaking up in the future?
  • Does anything need to change in your complaints handling system or approach to dealing with complaints?
  • Do staff require further training?
  • Did the handling of the complaint reflect your stated values and expectations for complaint handling? Or, was the complaint perceived as something negative that needed to be dealt with as quickly as possible?