Complaints, compliments and consumer feedback policy

The purpose of this policy is to:

• Provide direction to caregivers regarding collection, management recording and reporting of consumer complaints, compliments and feedback.
• Promote best practice in complaints management, for continuous improvement.
• Contribute to the St John of God Health Care Strategic Theme of Patient Experience and Clinical Excellence.

This policy applies to:

• St John of God Health Care Inc and any related body corporate, collectively referred to as “SJGHC”
• St John of God Health Care caregivers (all employed personnel)
• Contractors
• Visiting Medical Officers
• Student and volunteers
• Diocesan Catholic Chaplains and representatives of other faiths
• Trustees
• Board
• Other health practitioners, accredited or contracted, who provide care or services to patients, clients and caregivers of St John of God Health Care.

Collectively referred to as "caregiver".

Compliments, complaints and feedback policy

Consumers have the right to provide their feedback on the delivery of services, their treatment and caregivers at St John of God Health Care. This can be both positive (compliments, positive feedback) or negative (complaints or negative feedback). Complaints must be responded to in a timely, transparent and equitable manner and reviewed for opportunities to improve overall service delivery.

St John of God Health Care will:

1. Welcome and promote communication about care and service experiences from consumers and the community.
2. Provide all consumers with information as to how to provide complaints, compliments and feedback about St John of God Health Care services, including their ability to provide this information anonymously.
3. Meet the obligations for individual patient rights in healthcare in accordance with Patients and Consumers Rights and Responsibilities Policy.
4. Support systems for quality improvement and reporting on complaints, compliments or feedback from consumers.

St John of God Health Care Group Services will:

1. Refer any/all received complaints pertaining to a specific site/service, to the appropriate executive member for complaints handling and, where appropriate, an update will be provided to St John of God Health Care Group Services.

St John of God Health Care hospitals and services will:

1. Inform, widely publicise, and provide opportunity for consumers to provide St John of God Health Care with complaints, compliments and feedback, including providing details of external agencies who can receive complaints/feedback in accordance with Complaints, Compliments and Feedback Procedure. This may include, but are not limited:
   • admission packs
   • patient compendiums
   • service brochures
   • website information
   • displays in public areas
   • comment cards
   • surveys.
     Information provided will be made available in accessible and culturally sensitive formats in accordance with Inclusion and Diversity for Patients, Clients and Consumers Policy.
2. Provide assistance and support to consumers in making a complaint where applicable.
   • Assistance can also be provided by a relative, nominated representative or external advocate, if required.
3. Conduct complaints management:
   • Responsively, fairly, equitably, aligned with principles of natural justice and without prejudice by a process consistent with the Mission and Values of St John of God Health Care;Objectively, through a detailed review of the facts;
   • Confidentially;
   • Transparently where the complainant is provided with a detailed understanding of the complaints process and the anticipated timeframe for a response; and
   • Supportively, where complainants are identified as having additional needs (e.g.  language, literacy, physical, cultural, disadvantage).

Complaints and negative feedback

St John of God Health Care will:

1. Expect all caregivers to undertake management of complaints and negative feedback in accordance with their role, as outlined in Complaints, Compliments and Feedback Procedure.

Caregivers will:

1. Treat all complaints and negative feedback confidentially in accordance with Complaints, Compliments and Feedback Procedure.
2. Conduct complaints handling congruent with Open Disclosure Policy.
3. Utilise the relevant guidance for other complaints specific to:
   • Suspected abuse or neglect of consumers at in accordance with Safety and Protection or Children, Young People and Adults at Risk Policy.
   • Internal caregiver issues in accordance with Misconduct Policy
   • Health Practitioner impairment or notifiable conduct in accordance with Managing and Reporting Suspected Impairment of an Australian Health Practitioner Procedure.
4. Utilise Complaints, Compliments and Feedback Procedure to identify and action complaints, feedback or compliments accordingly.
   • Accord caregivers will undertake complaint, feedback and compliment management in accordance with Feedback and Complaints Procedure - Accord.
   • International Health caregivers will undertake complaint, feedback and compliment management in accordance with Complaints and Feedback Management Procedure - International Health.

Negative feedback

Caregivers will:

1. Identify that negative feedback is a straightforward matter and attempt to resolve this at the point of service, in accordance with Complaints, Compliments and Feedback Procedure.
2. Seek assistance from or escalate to a line manager if unable to resolve the negative feedback at the point of service.
   • If unable to effectively and reasonably resolve with assistance, action in accordance with complaints process.

Complaints

Caregivers will:

1. Acknowledge that a complaint is not a straightforward matter, and is unable to be resolved at the point of service.
2. Escalate to the caregiver responsible for complaints management at the relevant hospital or service.
3. Advise the complainant of action being taken to manage their complaint and assure them that (where applicable) their care, or the care of the person they have lodged a complaint on behalf of will not be negatively affected.

Caregivers responsible for complaints management will:

1. Respond to complaints in a timely, transparent and equitable manner in accordance with Complaints, Compliments and Feedback Procedure.
2. Use RiskMan (feedback module) to record:
   • Complainant demographics
   • Nature of complaints
   • Where applicable, link complaint to a clinical incident, including where this is retrospectively identified
   • Acknowledgement of receipt
   • Investigation findings
   • Actions taken
   • Closure of the complaint (including notification of the above to complainant).
3. Risk rate all complaints in accordance with the Complaints Risk Matrix.
   • Reporting of complaints in Riskman is mandatory.
   • The predominate source of negative feedback data is Qualtrics, however it is possible to report feedback data in Riskman, but this is not a mandatory requirement.

4. Coordinate the investigation and resolution of the complaint, including response (or delegation of the response) to the complainant.

5. Provide reports to relevant committees highlighting statistics, themes and trends for the purpose of implementing service improvements.

6. Report complaints and feedback data to relevant external agencies, including coordination with St John of God Health Care Group Services as required, in accordance with Complaints, Complements and Feedback Procedure.

Compliments

Managers will:

1. Address any compliments in accordance with Caregiver Recognition and Awards Policy.

Caregivers will:

1. Where indicated:
   • Acknowledge compliments and thank the consumer for providing the compliment.
   • Forward the compliment on to the appropriate caregiver/care team for local acknowledgement.

Training and education

St John of God Health Care hospitals and services must:

1. Set the tone for feedback and complaints management culture at orientation for new caregivers.
2. Provide education to caregivers to make them aware of local processes for negative feedback and complaints management and handling.

St John of God Health Care Patient Experience and Clinical Excellence (PEaCE) Team will:

1. Provide resources to support processes, standardisation and data entry for caregivers involved in negative feedback and complaint management handling.
2. Provide direction for discretionary external opportunities to support complaints management handling. (Open disclosure, difficult conversations, webinars of external agencies etc).

Caregivers must:

1. Understand the principals of acknowledgment and resolution of feedback at the point of care.

Social media and online feedback/complaints

Hospital and services marketing teams must:

1. Monitor and manage relevant St John of God Health Care social media channels.
   • Where a comment is identified as a complaint, the marketing team must refer it to the caregiver responsible for complaints management, for resolution, in accordance with Complaints, Compliments and Feedback Procedure.

St John of God Health Care Marketing Team will:

1. Provide further oversight of social media channels and notify hospitals/services when potential complaints are identified, for management.

Breach of policy

Failure to comply with this Policy by a member of St John of God Health Care may be considered a breach of the Code of Conduct and may result in disciplinary action.

Legislation 

• Health Complaints Act 2016 (Vic)
• National Disability Insurance Scheme Act 2013 (NDIS Act)
• National Disability Insurance Scheme (Complaints Management and Resolution) Rules 2018
• National Disability Insurance Scheme (Provider Registration and Practice Standards) Rules 2018
• NDIS (Quality Indicators) Guidelines 2018
• Mental Health Act 2007 (NSW)
• Mental Health and Wellbeing Act 2022 (Vic)
• Mental Health Act 2014 (WA)
• Privacy Act 1988 (Cth)

Authority

• Australia Commission for Safety and Quality in Health Care, (2020). National Safety and Quality Health Service Standards Guide for Hospitals. Second Edition. Sydney.
• Australian Commission on Safety and Quality in Health Care. (2019). Australian Charter of Healthcare Rights (second edition). Sydney NSW
• Australian Commission on Safety and Quality in Health Care (2005). Complaints Management Handbook for Health Care Services. Australia: Commonwealth of Australia.
• Australian Commission on Safety and Quality in Health Care (2004). Better Practice Guidelines on Complaints Management for Health Care Services Australia: Commonwealth of Australia.
• Australian Government: Office of the Australian Information Commissioner (2023) Accessed 5 May 2023 from https://www.oaic.gov.au/privacy/ptivacy-complaints
• Commissioner for Children and Young People (2013). Are You Listening? Guidelines for making complaints systems accessible and responsive to children and young people (2013) Western Australia
• Commonwealth Ombudsman (2023) Better Practice Complaint Handling Guide. Commonwealth Ombudsman, Canberra.
• Government of Western Australia Department of Health. (2020) MP 0130/20 Complaints Management Policy.  Perth WA
• Government of Western Australia Department of Health.(2020) WA Health Complaints Management Toolkit. Perth WA.
• Health Services Review Council (2011). Guide to Complaint Handling in Health Care Services. Victoria
• New South Wales Government: Health Care Complaints Commission (2018). Complaints. Accessed May 2023 from http://www.hccc.nsw.gov.au/Complaints/default.aspx
• New South Wales Health (2020) Complaints Management Policy PD2020_013. NSW Government. Sydney.
• Ombudsman New South Wales (2015) Complaint Management Framework. Crown Copyright NSW.
• Ombudsman Western Australia (2020) Guidelines on Effective Complaint Handling. WA Government, Perth.
• Standards Australia (2022). AS 10002:2022 Guidelines for Complaint Management in Organizations.Standards Australia
• The Government of Western Australia: Health and Disability Services Complaints Office (2023). Complaints About Health Services Accessed 3 May 2023 from http://www.hadsco.wa.gov.au/Complaints/Health-Services
• Victorian Government Health Information: Office of the Health Services Commissioner (2021). How to Make a Complaint About a Health Service Provider. Accessed May 2023 from https://www.health.vic.gov.au/participation-and-communication/how-to-make-a-compaint-about-a-health-service-provider
• Victorian Ombudsman (2016) Complaints: Good Practice Guide for Public Sector Agencies. Vic Government, VIC.

Glossary

Complaint

Anything that is not a straightforward matter and cannot be easily resolved at the point of service by caregivers.

• Requires escalation to a manger, a complaints coordinator, senior management or an external body.
• Can be received from a variety of mediums i.e. in person, phone, letter, drop box, email, online.
• Risk is categorised as either medium or high.
• In some literature a complaint by this definition is also referred to as a formal complaint.

Feedback

A straightforward matter, generally easily resolved at the point of service by clinicians and caregivers. Which does not require escalation to a manager.

• All caregivers are encouraged to solve negative feedback at the point of service, before frustrations and delay worsen the situation for a patient or their family/carer.
• Risk is low.
• In some literature, negative feedback is also referred to as an informal complaint.

Compliment

Any positive feedback about a caregiver, service or the organisation.

Stakeholders

Individuals or groups who are affected by, involved in or can influence development and implementation of development activities. For the St John of God International Health development activities, the word stakeholder will be taken to include beneficiaries, counterparts and development partners.