Standard 6. Feedback and complaints

Standard 6 requires an organisation to have a system to resolve complaints. The system must be accessible, confidential, prompt and fair. It should also support all consumers to make a complaint or give feedback. Resolving complaints within the organisation can help build the relationship between the consumer and the organisation. It can also lead to better outcomes.

The Standard covers key elements of an effective complaints management system that:

• encourages consumers to give positive and negative feedback to their organisation about the care and services they receive

• responds to feedback and complaints consumers and others make formally and informally, written or verbally to the organisation

• helps organisations keep improving, informs improvements to care and services and

• resolves issues for consumers and others.

Organisations are expected to demonstrate open disclosure. This is in line with up-to-date practices of open communication and transparent processes. It includes acknowledging and apologising when the organisation has made mistakes.

Consumers should feel safe and comfortable giving feedback to the organisation. Some consumers have barriers that make it difficult for them to raise complaints. These could be cognitive or communication difficulties, language or cultural differences. The nature of a complaint can also be particularly sensitive or private. Organisations are expected to look for ways to tackle these barriers and create a culture that welcomes feedback and supports consumers to make complaints.

Standard 6 links to:

Standard 1 – All aspect of care and services need to treat consumers with dignity and respect and support them to make choices. It’s also important that care and services are delivered in a way that is culturally safe. Feedback and complaints systems support the consumers to let the organisation know when this does not occur.

Standard 7 – Workforce interactions with consumers need to be kind, caring and respectful of each consumer’s identity, culture and diversity. In particular, the workforce needs to be capable of supporting consumers to raise feedback and complaints about any aspect of these Standards.

Standard 8 – The organisation’s governing body is accountable for the delivery of safe, and quality care, services and supports. It is expected organisation wide governance systems include feedback and complaints. The systems should support a culture of open disclosure and continuous improvement.

Intent of this requirement

This requirement describes how organisations need to welcome feedback and complaints as an opportunity to learn about ways in which they can improve outcomes for consumers.

Organisations must recognise that consumers have the right to raise concerns and make complaints about the care and services they receive from the organisation. The organisation must have in place best practice complaint handling and resolution systems that facilitate and support consumers to make complaints. Once made, the system follows principles of procedural fairness and natural justice and is managed in line with better practice guidelines.

The organisation is expected to demonstrate that they encourage and support consumers and their representatives to provide feedback or complain about the care and services they receive. This is based on consumers’ trust and confidence that there won’t be negative consequences if they raise concerns or complain.

It is expected consumers are made aware of and supported to access alternative, external complaints handling options, including the role of the Aged Care Quality and Safety Commissioner.

Reflective questions

• How does the organisation make sure everyone is aware of their right to provide feedback or make a complaint to the organisation? How is the complaint handling process publicised?
   
• How does the organisation make sure everyone knows how to use advocacy and complaint agencies outside of the organisation? How are advocacy services publicised?
   
• Are tools and information about feedback and complaints handling and resolution systems in plain English? Or in the consumer’s language? Are they presented in a format that can be easily understood?
   
• How does the organisation support diverse and vulnerable groups to give feedback and make complaints about their care and services?
   
• Does the workforce know how to access translation services and other communication and hearing support services to help consumers give feedback and make complaints?

Examples of actions and evidence

Consumers

• Consumers and their representatives understand how to give feedback or make a complaint.
   
• Consumers and their representatives say when they give feedback or make a complaint they feel comfortable and safe and aren’t treated in a negative way because of their feedback or complaint.
   
• Consumers and their representatives can describe what has been done in response to their feedback or complaint.

Workforce and others

• The workforce can describe how they encourage and support consumers to provide feedback and make complaints.
   
• The workforce demonstrate they are aware of and understand the operation of the organisation’s complaint handling system.
   
• The workforce can describe what they do when they receive feedback or a complaint and how the complaint handling process is in line with best practice complaint management.
   
• The workforce can describe how they are able to provide feedback where they identify issues in the delivery of care and services by the organisation.
   
• Workforce orientation, training or other records that show how the organisation has supports the workforce in how to handle feedback and complaints and the systems for complaints resolution.

Organisation

• Evidence of the organisation’s approach to feedback and complaints that describe the way it encourages and supports consumers, their representatives, the workforce and others to give feedback and make complaints.
   
• Evidence that the organisation prioritises appropriate receipt and management of complaints by consumers, their representatives, the workforce and others.
   
• Policy or process about the organisations system to manage complaints, including what consumers, their representatives, the workforce and others can expect when they provide feedback or make a complaint.
   
• Evidence that shows how the organisation protects the identity of those who want to give anonymous or confidential feedback or make an anonymous or confidential complaint.
   
• Availability of information about complaints and how complaints are managed by the organisation that consumers, their representative, the workforce and others can easily access.
   
• Complaints records or other evidence that show how the organisation has applied best practice in handling complaints.
   
• Evidence that the organisation monitors, reports and continuously improves its performance against this requirement.

Intent of this requirement

This requirement is intended to make sure that all consumers can easily make a complaint, whatever their culture, language or ability. The organisation’s complaints system should give every consumer equal access to make a complaint.

Consumers may have barriers to using the complaints system, such as diversity of culture or language. Poor vision, hearing loss, or cognitive impairment can also make it difficult for some consumers to make a complaint.

It is expected consumers are also made aware of and supported to access services that can assist them to make a complaint. This includes support to access alternative, external complaints handling options, including the Aged Care Quality and Safety Commissioner.

Reflective questions

• How does the organisation let consumers know about advocacy services? How does it let consumers know about using external agencies to resolve complaints?
   
• Is information about complaints available in languages and formats consumers can use?
   
• How do members of the workforce recognise when a consumer needs help to use an advocate or other support service?
   
• Do the complaints the organisation receives reflect the diversity of consumers using the service? If not, are there barriers to some consumers making a complaint or accessing an advocate?

Examples of actions and evidence

Consumers

• Consumers and their representatives know how to access advocates. They know how advocates can help them raise and resolve complaints.

• Consumers can describe how the organisation has used language services, hearing assistance and other communication aids to support them to communicate their complaint directly or via an advocate.

Workforce and others

• Members of the workforce can describe how they identify consumers who may need help to raise a complaint or use an advocate.

• The workforce know how to contact advocacy and language services.  Members of the workforce can describe how they have helped consumers to communicate issues and make complaints via advocates and using interpreters.

Organisation

• Evidence that the organisation has involved advocacy services and community groups, which represent the diversity of its consumers, to improve consumers’ opportunities to raise issues and resolve complaints.

• Meeting records or other evidence that the organisation actively asks for feedback from advocates and access language services when consumers need assistance.

• Evidence of an effective assessment process that identifies the support that consumers need to make a complaint.

• Evidence of how the organisation monitors, reports and keeps improving its performance against this requirement.

Intent of this requirement

This requirement covers the actions that an organisation is expected to take in response to complaints. It’s expected that the organisation will have a best practice system for managing and resolving complaints for consumers.

To create an environment that reduces harm to consumers, organisations need a culture where people feel supported and are encouraged to identify and report negative events. This gives organisations opportunities to find and act on things that can improve their systems. This includes how the organisation recognises when something has gone wrong that could harm, or has harmed, someone. The organisation is expected to tell the consumer about this, apologise, and explain what has happened. They should also explain why it happened and what they are doing to prevent it from happening again.

Reflective questions

• What systems does the organisation have to make sure complaints are followed up and appropriate action is taken?
   
• When things go wrong, how does the organisation go about understanding what has happened?
   
• How does the organisation involve consumers? How are consumers able to add to information about a negative event and, where possible, take part in the incident review and in finding solutions and outcomes from complaints?
   
• When things go wrong, are there clear responsibilities within the organisation for communicating with consumers and their representatives so that they receive the information they need to understand what happened?
   
• What has the organisation done to promote and support a culture of learning from mistakes? What has it done to implement and sustain the changes needed in care and services from lessons learned?
   
• How does the organisation use the advice of advocates and community representatives to understand the best and most appropriate way to resolve a complaint for a consumer?

Examples of actions and evidence

Consumers

• Consumers and their representatives are confident that the organisation acts appropriately and promptly when responding to feedback and complaints.
   
• Consumers are involved in finding options to resolve a complaint.
   
• Consumers feel that the organisation has given them an honest explanation from the organisation when things have gone wrong and are reassured that it won’t happen again.
   
• Consumers aren’t afraid the organisation will treat them badly after making a complaint.

Workforce and others

• The workforce can describe the complaint handling system in place in the organisation, and give examples of responding to complaints.
   
• Members of the workforce can provide examples of communicating with a consumer about a complaint and what the organisation is doing to resolve it.
   
• If something has gone wrong, members of the workforce can describe how the organisation took an open disclosure approach to communicating with consumers, their representatives and others.
   
• The workforce say the organisation encourages them to acknowledge mistakes without being afraid of the consequences.
   
• Workforce orientation, training or other records that show how the organisation supports the workforce to meet this requirement.

Organisation

• Records that show application of a best practice complaints management system in operation for the organisation.
   
• Evidence that shows the organisation has clear responsibilities and timeframes for responding to complaints.
   
• Documented complaints and incidents. Evidence shows that the organisation has included consumers to find solutions and taken appropriate action.
   
• Policies and procedures that show how the organisation asks for feedback from consumers and representatives about how satisfied they are with the complaints management system.
   
• Evidence that communication by the organisation after adverse events is open, honest and timely. This may include communication between consumers, their representatives, members of the workforce and where relevant, between organisations.
   
• Evidence of how the organisation monitors, reports and keeps improving its performance against this requirement.

Intent of this requirement

The organisation is expected to have a best practice system to manage feedback and complaints. Organisations should use this system to improve how they deliver care and services.

As well as encouraging complaints and asking for feedback, the organisation should provide timely feedback to the organisation’s governing body, its workforce and consumers on complaints and the actions the organisation took. It’s expected that the organisation will use information from complaints to make improvements to safety and quality systems and regularly review and improve how they manage complaints.

Reflective questions

• How does the organisation monitor, analyse and use feedback and complaint data to improve the quality of its care and services?
   
• How does the organisation share what it has learnt? 

• How does it share improvements that have come out of feedback or complaints internally and with other relevant organisations?
   
• How does the organisation involve consumers and the workforce in reviewing information from feedback and complaints to improve their care and services?

Examples of actions and evidence

Consumers

• Consumers and their representatives are confident the organisation uses feedback and complaints to improve the quality of their care and services.
   
• Consumers can describe a range of ways they can be involved in finding solutions to issues that they have raised in feedback or complaints.
   
• Consumers can describe how the organisation informs them of processes available to escalate complaints if required.
   
• Consumers can describe ways that the organisation has learnt from complaints and made improvements to their service.

Workforce and others

• The workforce can describe how the organisation records, analyses and acts on feedback and complaints to improve the quality of their care and services.
   
• The workforce can describe how feedback and complaints are used to improve the quality of care and services delivered.
   
• Workforce orientation, training or other records show how the organisation supports the workforce in using feedback and complaints to continuously improve the service.

Organisation

• Evidence that the organisation monitors feedback and complaints.
   
• Evidence that complaints are escalated so that they go to a member of the organisation with authority to make a change.
   
• Evidence of how the organisation monitors, reports and keeps improving its performance against this requirement.

• Aged Care Act 1997 (Cth), User Rights Amendment (Charter of Aged Care Rights) Principles 2019