Practical guide: Feedback & complaints process

Prime Minister Anthony Albanese has spoken lovingly of his mother Maryanne, and how they lived in public housing sustained by her disability pension. In an interview, he proudly remarked that “she never complained”. While historically it may seem the gold standard to never complain, perhaps a reinterpretation of the narrative could be “she never had anyone to complain to”.

Thankfully, participants now have every right to complain about the safety and quality of their supports and services, and the NDIS Quality and Safeguard Commission upholds the responsibility for both registered and unregistered providers to have a complaints process that places the participant at its centre.

Here is a practical guide to ensure your organisation is in position to receive and act on feedback, even from someone as important as the mother of a future Prime Minister of Australia.

Policies, procedures, and practice

Your Feedback and Complaints Policy will uphold the right for participants to provide feedback about the supports they receive. The accompanying Feedback and Complaints Procedure will ensure that everyone in your organisation has a step-by-step process to manage feedback. Meeting NDIS Practice Standards and passing an external audit will require your organisation to demonstrate how you put these policies and procedures into everyday practice.

Providers need to have a “robust governance and operational management system”, proportionate to the size, scale, and complexity of the supports delivered. Your Complaints Management and Resolution System will form part of meeting your responsibilities, as outlined in NDIS Practice Standards and Quality Indicators Core Module, Section 2.

Request feedback

There is a saying: “welcome feedback before it becomes a complaint”. Feedback from participants can be positive or negative, and complaints are not always criticisms. If providers are prepared to lean in and listen to the views and voices of participants, those suggestions could hold the key to continuous improvement and sustainable success.

Encourage participants to give honest feedback using their preferred method of communication:

• by phone or text

• via email

• through your website

• by snail mail

• an option that allows for anonymous feedback such as a self-addressed postcard or an incognito online feedback submission

• attach a footnote to your email signature welcoming feedback

• link and share a resource such as Make it Better – Making a Complaint, a short video created by the NDIS Commission that is aimed at First Nations participants and incudes Auslan translation

Respond promptly

A prompt response acknowledging receipt of a complaint demonstrates that your organisation cares. Politely thank the participant for taking the time to bring feedback to your attention and apologise that his or her expectations haven’t been met. Offer reassurance that your complaints management process will be followed and provide a timeframe for when the participant can expect further communication.

Keep records

NDIS quality auditors will review the Complaints Management and Resolution System as part of your initial and mid-term audit to ensure your organisation is meeting practice standards. Auditors are delightfully curious, so the absence of any participant feedback records would arouse suspicion.

Your Complaints Management and Resolution System needs to be “proportionate” to your organisation. This could be as simple as recording relevant information on a spreadsheet or form part of a broader Customer Relationship Management system. The information to record must include

• information about the complaint,

• any action taken to remediate or resolve the complaint, and

• the outcome of any action taken

Records should be maintained for seven years and must be managed in a way that respects privacy, confidentiality, and the rights of people making complaints.

Take responsibility

There is a difference between assigning blame and taking responsibility. While your staff and your organisation may not be entirely at fault for the circumstances giving rise to a complaint, the act of taking responsibility to investigate is the first step to repairing, and possibly even strengthening, the relationship with your participant. These could include statements such as:

• I acknowledge how disappointing/frustrating/upsetting this must be for you.

• I sincerely apologise that this has added to the stress in your life right now/caused confusion.

• I can see that this support has not lived up to our organisational values/met with your expectations.

• We will follow steps for performance management/process adjustment for incorrect payment requests.

• We will continue to work with you to seek a satisfactory solution.

Resolution

Often, the resolution of a participant complaint is hiding in plain sight. Is the participant requesting an apology, an explanation, a refund, or a change of personnel? If that is not clear, then don’t be afraid to ask the participant a simple question: ‘What can I do to resolve this for you?’

If your resolution isn’t satisfactory or isn’t your responsibility, then participants should be directed to

• the NDIS Commission for complaints about providers,

• the National Disability Insurance Agency for complaints about that agency and, if still unhappy, escalation to the Commonwealth Ombudsman, or

• the Australian Competitor & Consumer Commission for complaints about products and services.
  

Reflection

Perhaps the most valuable opportunity feedback provides is an impartial evaluation of your supports, service, and staff. Review the records in your Complaints Management and Resolution System to look for patterns and opportunities for continuous improvement.

Is there a staff member’s name that appears more often in complaints? This could be an indication of the need to manage underperformance.

Is there a process or procedure in your organisation that is triggering complaints? Consider automating manual tasks or, conversely, adding a personal touch to create warmth and connection.

Don’t forget to seek participant views on the accessibility of your Complaints Management and Resolution System and incorporate their feedback throughout your organisation.

A final reminder of the need to make staff aware of, trained in, and compliant with feedback and complaints policy and procedures. The best way to do this is keep the topic of NDIS Quality and Safeguards on your team agenda. DSC also has Fora courses for managers and support workers that break down handling complaints in line with the Commission’s compliance requirements.

We hope you found this guide useful – if you would like to provide feedback, you can do so on our website, via phone or by email.