Feedback and Complaints Policy

1. PURPOSE

DCIRS values feedback and complaints from people accessing disability and aged care services, families, carers, service providers and regulators to ensure the quality of our services and the fair treatment of those using our services. Feedback and complaints are an important source of information and are used to inform and improve our services wherever possible. This Policy will commence from 14 March 2024. It replaces all other feedback and complaints policies of DCIRS (whether written or not).

2. APPLICATION

This Policy applies to:

• Staff and contractors performing services, and DCIRS agents.

• Clients and participants and their families and informal supports.

• Linked agencies, such as Support Coordinators, Plan Managers, and Health Providers.

This Policy does not form part of any employee’s contract of employment.

3. DEFINITIONS

Allegation – a claim that an illegal act has occurred. Allegations are always investigated and sometimes an external authority undertakes the investigation, such as the police.

Complaint – formal advice that an incident has occurred, something is not working the way it should, something is inappropriate or someone is at risk. A serious incident process is required for legal and contractual purposes when a complaint is about a serious incident.

Concern – a notification that a person is worried that something is not working, has gone wrong or is otherwise not as it should be.

Feedback – written or verbal information provided to DCIRS by its stakeholders that is used to improve services, whether such feedback is negative, positive, or neutral.

4. POLICY

This Policy is informed by relevant legislation pertaining to the rights of individuals across disability, aged care, and employment spheres.

Principles

DCIRS adheres to the following principles:

• Anyone receiving a service or supporting someone else to access a service has the right to reasonably raise a grievance or complaint about the service.

• People making complaints should be supported to access complaints processes.

• Complaints processes should be sensitive to any cultural requirements.

• Robust feedback and complaints processes and systems are an important part of quality service management and help safeguard people with disability.

• Feedback and complaints can help to identify risks to clients and participants as well as visitors and staff, and support DCIRS to meet its occupational health and safety obligations.

• Complaints may identify opportunities for DCIRS to continuously improve its services

DCIRS is aware that making complaints can be stressful. Complainants should be aware that aggressive behaviour, verbal assault, or physical assault will not be tolerated. Such incidents of aggression will be escalated accordingly to protect the individuals involved.

Procedure

This procedure supports DCIRS to apply the National Disability Services Standards and Aged Care Standards relating to feedback and complaints.

Complaints can be received verbally, in writing, or by an alternate method convenient to the person making the complaint. The complaint needs to be made in such a way that it is recognisable as a complaint so that DCIRS can promptly deal with it. Families, carers, and advocates can make a complaint on behalf of a client or participant.

If someone makes a complaint to a DCIRS worker, that worker is responsible for recording the complaint. Complaints should be documented on DCRIS’s Complaint Form within 24 hours of being made. It is important that the worker checks with the complainant to ensure the complaint has been recorded accurately. The complaint will also be lodged in the Complaints Register.

At any stage of the complaints process, the complainant or the alleged offender (where relevant) can obtain support from an independent advocate or support person.

Confidentiality must be maintained during the complaints process. Complaint information is private and must not be shared with people outside of the complaints process. This clause does not prevent any person from engaging their support person during the process.

A Complaints Officer will contact the person who lodged the complaint within five working days to discuss the matter. Details of the complaint and any response will be documented. The Complaints Officer and / or a DCIRS manager will work with the person lodging the complaint to identify desirable outcomes, with an aim to resolve the complaint within 21 working days.

If the complaint is against an employee or volunteer, that person will not have contact with the complainant while the complaint is in progress. Where an allegation is made against an employee or volunteer, the person alleged to have caused the complaint must also be treated fairly. Any internal investigation must apply the principles of natural justice and adhere to DCIRS’s internal policies. Where a matter needs to be referred to an outside agency or otherwise investigated, workers will cooperate with the inquiry and produce material as reasonably requested.

The following types of complaints must be dealt with in accordance with the relevant reporting framework (i.e. NDIS or Aged Care):

• serious incidents;

• allegations of abuse, neglect or exploitation;

• theft; and/or

• accidents, injuries, or death.

Senior management will decide whether other policies and procedures apply, such as Safeguarding, or Eliminating Restrictive Practices policies and will determine whether measures need to be included in a positive behaviour or safeguarding plan.

Responsibilities

All employees, contractors, and agents of DCIRS are responsible for the implementation of this policy and procedure. This includes encouraging and supporting clients and participants accessing services to raise any concerns or complaints they have on any issue. The Complaints Officer is responsible for ensuring complaints are recorded and actioned. The Complaints Officer is responsible for communicating with people with disability, family, carers, and other key stakeholders during a complaints process. Being able to freely make a grievance or complaint does not mean the right to treat another individual with disrespect, no matter how frustrating it is. Complainants must raise their complaint in a manner that is clear, respectful, and allows DCIRS a reasonable opportunity to address the issues. Rude or offensive behaviour towards staff or other workers will not be tolerated. Staff experiencing such behaviour must report it immediately. In the same way, DCIRS workers must maintain the dignity of those making a complaint.

Reporting

DCIRS’s employees and contractors must report all serious incidents to their manager and follow the Incident and Risk Reporting Policy as soon as they become aware of the issue. Police will be contacted in the event of a criminal allegation.

Review and evaluation

DCIRS will communicate with its clients and participants about quality evaluations and encourage their participation in evaluating services. At least twice a year senior management will analyse complaints data to determine service gaps, issues or trends in practice, procedures or policies that need to be amended to better safeguard people accessing services and improve services.

Key contact

Questions about how to implement this Policy and its Procedure should be directed to Emily Mills, Managing Director, by emailing emily.mills@dcirs.com.au.

5. ASSOCIATED DOCUMENTS

• Incident and Risk Reporting Policy

• Incident Report Form

• Feedback and Complaints Form

• Complaints Register

• Continuous Improvement Policy

• Code of Conduct Policy

• Safeguarding Policy

DCIRS upholds the laws of Australia and the states and territories in which it operates, including all laws relating to the protection and rights of the parties covered by this Policy.

6. VERSION AND REVIEW INFORMATION

DCIRS reserves the right to amend and vary this Policy from time to time.

Version 1.0: 23 November 2020

Version 2.0: 14 March 2024 Review date: 14 March 2027

Version 2.5: 28 March 2025 Review date: 14 March 2027