Customer Service Solutions for Government and Public Sector Conference - 11 June 2014

Complaint handling by Commonwealth agencies – the state of play

Richard Glenn, Deputy Commonwealth Ombudsman 

Introduction 

Thank you.

Ladies and gentlemen, it’s a pleasure to be here with you this morning to talk about complaint handling by Commonwealth agencies. 

First of all I’d like to acknowledge the traditional owners of the land on which we meet, and pay my respects to their elders, both past and present. 

Last month’s federal Budget and the recent report by the Commission of Audit highlight the changing environment for public sector agencies. 

In a time of economic constraint, it is tempting for government bodies – and some private sector organisations for that matter – to give less regard to functions like complaint handling. They might be referred to as ‘fringe’ activities and the resources deployed to deal with them reduced. 

As representatives of the three tiers of government, who are clearly interested enough in customer service to come to this conference, I’d like to imagine that everyone here would think in just the opposite terms; that it’s just the environment not to be ignoring complaint handling. 

During this presentation I will talk about the role of the Office of the Commonwealth Ombudsman. Then I’ll discuss some of the trends in complaints that we’re seeing. 

And I’ll finish up with an early look at our investigation into complaint handling by Australian and ACT government agencies. 

The Ombudsman’s role 

Ombudsman institutions have been around in Australia for almost 40 years, handling complaints about every tier of government – federal, state, territory and local. 

More recently we have seen the emergence of a range of industry Ombudsmen schemes handling complaints about firms operating in particular industries. 

The number of matters handled by Ombudsmen each year is impressive. 

For example, each year our office will receive around 23,000 approaches (that is, people approaching us to complain) from individuals, groups or organisations, and we will formally investigate several thousand of them. 

The issues raised with us range from the simple to the complex, across all the activities of government – a decision delayed, a letter that can’t be understood, a benefit wrongly withheld, a visa denied, lost records, and alleged corruption are some examples. 

The notion is now embedded that people have a right to complain about government, without hindrance or reprisal, and to have their complaint resolved on its merits. 

But of course ombudsmen don’t exist in a vacuum. Most people’s interaction with government won’t be with an ombudsman, but rather with the agency that is providing them with a service. 

That means the first opportunity to deal with a complaint is in the hands of the agency. This is, of course, as it should be. 

But agencies’ willingness to engage with, resolve and seek to learn from complaints is a feature of the public sector landscape that differs from the landscape when ombudsman offices were set up.

And that make the relationships between agencies and ombudsmen, and ombudsmen and citizens, different from what they once were. 

It’s best summed up by the idea that agencies deal with complaints, while ombudsmen deal with disputes. 

Agencies are the first to receive and seek to deal with complaints. If the customer is not satisfied, they take their dispute with the agency to the Ombudsman. 

That makes the Ombudsman very interested in agency complaint-handling systems. The better they work, the fewer disputes come through to us. 

Where an agency has a complaint-handling process that is well publicised, our office is less likely to receive direct complaints about that agency. 

When complaints are directed to the agency in the first instance they are, in most cases, resolved in a relatively timely and cost-effective manner. 

The agency’s relationship with the complainant is improved as a result of the interaction, and the complaint provides the learning that can be incorporated into the agency’s systems through continuous improvement. 

To this end, we often help agencies develop service charters and effective complaint handling systems. This is an important investment for us because we see the results when things go wrong. 

If a dispute does come to us, we may investigate it with an emphasis on speedy resolution and an eye to ensuring systemic improvement to public administration generally. 

Most investigations are conducted informally, but more complex investigations may require the review of many files and documents, formal interviews and independent specialist advice. 

The Commonwealth Ombudsman may also choose to use his ‘own motion’ power to initiate an investigation. This often follows receipt of several complaints about the same issue, indicating a recurring problem. 

We have almost completed an own motion investigation into Commonwealth agency complaint handling. I’ll elaborate on that in a few moments. 

Trends in complaints and what does the future hold 

But first I’d like to talk a little about the trends we’ve been seeing in complaints across government.

In the financial year to the end of April, within-jurisdiction approaches to our office were down 5 per cent (to 15,097).

But that’s an average. Complaints about some agencies in our jurisdiction are falling, while others have increased. I’ll expand on some of those areas. 

Own motion into complaint handling

Earlier I mentioned that we had almost completed an investigation into agency complaint handling. 

We expect to publish the report of that investigation later this year, but I’d like to share with you some of the key points that have emerged so far. 

The first thing to say is that our investigation confirms a conclusion we’d made based on anecdotal evidence: there is a very diverse approach in how agencies approach complaint handling – from the very good to the, well, not so good.

And there certainly isn’t a one-size-fits-all approach that can be applied. 

Our investigation has three main strands. 

First, to describe the existing state of complaint management. This will then provide us with a benchmark into the future.

Second, to analyse to see what is not working and why. This will allow us to identify high-risk areas and trigger points. 

And third, to revise our Better Practice Guide, setting out the principles of good complaint handling and what an effective complaint handling system looks like and needs to have. 

Current state of agency complaint handling 

We asked about 150 government agencies to fill in a survey and received about a 65 per cent response rate, which we were very pleased with. 

The result is the most comprehensive snapshot of Commonwealth complaint handling that has ever been done. 

I should point out that our analysis of the survey results is mostly qualitative. Some organisations completed separate survey forms for different programs, which was very helpful, but that makes quantitative analysis less reliable.

But there are some things we can say about complaint numbers. 

It is clear that many factors influence raw complaint numbers so the number of complaints cannot, in itself, be an accurate indicator of agency performance. 

Many factors that go towards improved performance, such as increasing the focus on complaints and rigour around recording them, can increase raw complaint numbers. 

Equally, a reduction in numbers may be due to a change in responsibilities rather than an improvement in agency performance. 

In some situations, the number of complaints did not necessarily increase, but centralised recording of all complaints became more widespread. 

For example, the Department of Veterans’ Affairs created a specific Feedback Management Team in 2010, resulting in increased training and awareness of the complaints system across all DVA staff. 

This greatly increased staff recording of complaints, with DVA reporting an eight-fold increase in complaint numbers from 2008-09 to 2009-10. 

Another relevant factor is raising public awareness of either the organisation or the complaints mechanism. The Civil Aviation Safety Authority noticed an increase in complaints, and partially attributed it to an outreach program raising the profile of the Industry Complaints Commissioner.

For smaller organisations, a single issue can result in a marked difference to their complaint numbers. The National Library reported that reduced parking was the main factor driving their complaint increase. 

So, raw numbers tell us something but not the whole story. What else is important to think about when looking at complaint handling? 

Quality. 

We asked agencies whether they thought the quality of their complaint handling had improved or deteriorated. 

Not surprisingly, no agency admitted to having worse complaint management than they did five years ago. In fact by far the biggest group thought the agency had improved markedly in the past five years.

Even allowing for a bias towards positive self-reporting, this shows complaint management tends to be included in organisational continuous improvement.

Fifty-seven agencies had had either internal or external reviews of their complaint system in the previous three years. This represents about two-thirds of the agencies that responded to our survey. 

Agencies were asked what elements contributed to improved complaint management. 

Improved processes was the most common reason. 

This is consistent with our office’s view that good complaint management has many factors in common with good case management. 

Clear and sensible processes support every aspect of complaint management, in particular efficiency, fairness and responsiveness. 

But the second cause for improvement was less expected; not because it isn’t important but because we didn’t think it happened that much: senior leadership support. 

Senior leadership support is vital for organisational changes, particularly cultural changes such as creating or fostering a culture that values complaints.

In our survey we specifically asked who the senior management owner of the complaints process was. Fifteen responses nominated the Chief Executive Officer or Commissioner, 58 indicated a Senior Executive Service level officer, and a further 10 stated it was a manager. 

Even allowing for discrepancies in position titles, the responses show that complaints processes are commonly the responsibility of senior officers. 

Agencies were also asked to list any other reasons for complaint management improvement that did not appear on the survey list. 

The three most common additional reasons were:

Interestingly, increased resources was quite low on the list. This may be because no-one had actually received more resources, but it could also be because it is only one of the smaller factors in improving agency complaint management. 

What did we find were the tricky bits for agencies? As you can imagine, there were several. 

First point of contact resolution 

We asked agencies whether they recorded expressions of dissatisfaction that were resolved at the first point of contact as complaints. 

Of the 107 responses to this question, only 31 said that they recorded these contacts as complaints.

Several organisations qualified their response by saying that it differed across the agency, or that complaints were recorded in some circumstances. 

For example, the Global Feedback Unit in the Department of Immigration and Border Protection records these matters as complaints if they are received by the unit in the first instance. 

However if the matters are received and resolved elsewhere in the department then they are not recorded as complaints. 

Again, there is no right or wrong way to record first point of contact resolution, but the benefits of always recording these interactions are it: 

And the disadvantages? 

Each agency needs to weigh the advantages and disadvantages. An important first step would be to find out how much first point of contact resolution takes place already. 

It may be there’s a whole lot of effective complaint management going on that isn’t being taken into account. 

Complaints handling by line areas vs designated complaints areas 

We asked agencies if complaints were resolved to finalisation by the designated complaint handling area or by line areas in the organisation. 

Allowing for differences of detail, the agencies fall into broad groups. Here’s a table that illustrates the point: 

There is no right or wrong way to manage complaints. The approach has to be fit for purpose for each individual agency. 

But there are advantages and disadvantages to each model, and the correct model for each organisation will depend on a range of factors. 

Generally, some things are easier or harder with each model (see below): 

 CentralisedLine area
Consistent handling of complaintsEasierHarder
Training staff in complaint management Easier Harder
Accurate and complete record keepingEasierHarder
Resolving problems at the first contactHarderEasier
Providing a remedyHarderEasier
Feeding complaint information to senior managementEasierHarder
Integrating complaint information into changes to business practicesHarderEasier
Dealing with complaints independently and without preconceptionsEasierHarder

It is also possible to set up any type of hybrid model. For example, the Australian Federal Police operate a type of triage system depending on the subject matter or content of the complaint.

Prior to legislative changes in 2006, the AFP dealt with all matters in a central area with the same degree of formality. This resulted in some delays for minor matters which could have been dealt with speedily by the line officers. 

So now, less serious matters are dealt with by the line area where complaints raising more serious concerns are referred to the central area for investigation and resolution. 

Organisations with discrete programs may also find that the benefits of centralisation are more than offset by the difficulty of training a centralised officer to be sufficiently knowledgeable about the organisation’s business. 

For example, each program in the Bureau of Meteorology has its own system for handling and responding to complaints. 

The bureau advises that “the diversity of products and services the bureau offers make it more efficient for the business area to respond”. 

It is also relevant that the bureau gets very few complaints – one or two a month – meaning that carrying a complaint load is not an unreasonable burden for business areas.

Referrals and transfers 

An area of complaint management that is easy in theory, but challenging in practice, is the processes for referring matters to other organisations, and receiving matters that other organisations have referred. 

The principle is quite straightforward; if one organisation receives a complaint that another organisation is best placed to resolve, then the matter should be transferred. In practice, this presents multiple challenges.

First, determining and addressing the issues to be resolved. Members of the public do not always know which part of government is responsible for their problem and are not always clear about the different aspects of their complaint. 

An important part of training for first point of contact complaint staff is how to disentangle the issues and translate the experience of the complainant into a structure and form that can be recognised by the bureaucracy. 

Second, ensuring that any referrals or transfers comply with the legislative framework. 

There are strict rules governing when a public sector body may disclose information about a person and these need to be reflected in agency policies. Often, consent of the complainant will be required. 

Third, establishing upfront the ongoing responsibility for resolution, and communicating that to the complainant. 

Complaints to our office that involve multiple organisations often include a complaint about a lack of communication from the first agency. 

The first agency thought its obligation was discharged when the matter was transferred, but the complainant thought the agency would contact them again to finalise the matter. 

We asked agencies whether they had a process for referring complaints to other organisations. Of the 107 responses to this question, 61 had a process, 36 did not, and 10 organisations said the question was not applicable to their work.

The process of the Australian Customs Service is representative: 

Where a complaint relates to the actions of another agency, the Complaints and Compliments Management Unit contacts the client to provide them with the contact details of the relevant agency. The complaint details are not provided to another agency directly, as it may contain personal information. 

Another way of managing referrals out is to retain some degree of oversight of the resolution of the complaint. This is common within organisations – where a centralised complaint management area will refer a matter to a line area for resolution while retaining a general oversight role – but less so between organisations. 

The Australian Rail Track Corporation oversights in some circumstances: 

Complaints are received and logged in our system. If, following initial investigation, they are found to be the responsibility of a rail operator or another organisation, then they are referred by email to the appropriate person in that organisation for either a) a response to the complainant directly, or b) advice to ARTC so that ARTC can provide a response back to the complainant. 

The main challenges that still exist 

Most agencies we surveyed dealt with vulnerable people. 

Vulnerable people have a higher propensity to need access to a complaints process because they are more likely to fall out of the machinery of public administration. 

Problems with access, literacy, mobility and understanding lead to greater difficulty in accessing public services, or a greater likelihood of falling foul of regulatory authorities. 

The natural tendency is for public sector organisations, with limited resources, to focus their attention towards the greatest good for the greatest number, with fewer resources devoted to those who are more problematic. 

The role of a good complaint system is to act as a safety net, and put people safely back in the system with no loss of entitlement and with a minimum of stress to all concerned. 

However, this process is made more difficult by the very attributes that make it more likely that people will have a complaint in the first place. 

It is therefore critical that a complaint system places a great deal of emphasis on being accessible to vulnerable groups. 

When dealing with people there must be some flexibility in the system to deal with those who fall towards the edges. 

Our survey uncovered – or confirmed – three key aspects to providing flexible complainthandling systems. 

First, you have to remove the barriers. Reaffirming the right of a client to complain, and making a public statement of your organisations’ commitment to that right, must be more than mere words. 

One significant, if intangible, barrier to complaints is the preconception that it won’t make a difference; that nothing in government will ever change. 

Emphasising openness, listening, trust and transparency can affect someone’s decision as to whether or not to attempt to fix their problem. 

Presenting your complaint system in a way that is distant, formal and unsympathetic can in itself be a significant barrier to access. Feedback mechanisms should be easily and widely accessible. 

The avenues of complaint and the information provided should be in simple language, available through a variety of mechanisms and widely understood. 

These mechanisms should be approachable, simple and responsive to circumstances. 

Second, make lots of channels available. In one good example from the survey, Australia Post allows complaints to be made directly onto its Facebook page, with staff providing a response in the same way. 

Both the complaint and response are public, with anyone able to read the issues and replies. 

For many people a Facebook page is a non-threatening and straightforward way of requesting advice or giving negative feedback, without the perceived formality of an email (let alone a letter), and the wait associated with a voice call to any large call centre. 

Third, assist people through the process. Five organisations stated specifically that they took action to modify their complaint process to meet special needs. 

This can be quite simple, for example the Australian National Preventative Health Agency advised that they may waive or change timeliness requirements in order to effectively deal with a complaint.

Both the Australian Taxation Office and the Office of the Registrar of Indigenous Corporations advised that they can meet complainants face to face if necessary, at a location convenient to the complainant, and outside their offices where required. 

Many organisations also have specific policies that govern their dealings with vulnerable groups in all circumstances, including during the complaint process. For example, the Australian Federal Police has comprehensive policies on how they interact with young people. 

Finally, and perhaps most importantly, building a culture that supports complaints. 

One of the main influences on best practice complaint handling is fostering a culture that values complaints. 

Good complaint management requires individual staff members to see complaints as valuable and to know that dealing well with complaints is an important part of their job. 

We asked agencies, firstly, if they fostered a culture that values complaints. Ninety-three agencies replied that they did, six replied that they did not. We asked agencies to describe the ways they fostered a culture that values complaints. The most common response was that their organisation treated complaints as a valuable source of information for continuous improvement. 

This view – that complaints are useful to an organisation – is now almost universally accepted. However, this is a change in attitude in the Australian Public Service over the past 20 years. 

In our first Good Practice Guide to Effective Complaint Handling, published in 1997, the then Government had just announced that public sector agencies would, for the first time, be required to have customer service charters. 

Our guide started with a chapter on client service in the public sector and needed to state: 

The importance of good client service in the public sector is often overshadowed by the need to cut costs and do more with less. Unfortunately, good client service is sometimes considered a luxury that the public service cannot afford.i

From the responses we received in the survey, it seems that agencies no longer believe that good client service is a luxury, even though it may not be achieved to a high enough standard enough of the time. 

Other ways in which agencies fostered a culture that values complaints included regular training for staff, internal communication reinforcing the value of complaints, strong support from senior management, and by emphasising complaint processes during the induction of new officers. 

Conclusion 

So what would I like you to take away from today? 

First, the importance of complaint handling. I think I’m preaching to the converted on that point, but it is always worth making. 

Complaints are a tremendous source of intelligence – they have real business value and those who deal with complaints and complainants have real value within their organisations. 

Second, there’s no one-size-fits-all solution to dealing with complaints. Every organisation needs to work out what is going to be fit for purpose. 

But in doing that, we know some things that make organisations more likely to succeed than to fail. For example: 

These are things we know intuitively, but our investigation into agency complaint handling is providing evidence that we are right. 

I’m hopeful we’ll find out more as the investigation continues and I look forward to sharing that with you shortly with the release of our report. 

But for now I’d like to thank you for listening and wish you all well for the remainder of the conference. 

Thank you. 

i A Good Practice Guide for Effective Complaint Handling 1999 reprint

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      11 June 2014: Customer Service Solutions

      Customer Service Solutions for Government and Public Sector Conference - 11 June 2014

      Complaint handling by Commonwealth agencies – the state of play

      Richard Glenn, Deputy Commonwealth Ombudsman 

      Introduction 

      Thank you.

      Ladies and gentlemen, it’s a pleasure to be here with you this morning to talk about complaint handling by Commonwealth agencies. 

      First of all I’d like to acknowledge the traditional owners of the land on which we meet, and pay my respects to their elders, both past and present. 

      Last month’s federal Budget and the recent report by the Commission of Audit highlight the changing environment for public sector agencies. 

      In a time of economic constraint, it is tempting for government bodies – and some private sector organisations for that matter – to give less regard to functions like complaint handling. They might be referred to as ‘fringe’ activities and the resources deployed to deal with them reduced. 

      As representatives of the three tiers of government, who are clearly interested enough in customer service to come to this conference, I’d like to imagine that everyone here would think in just the opposite terms; that it’s just the environment not to be ignoring complaint handling. 

      During this presentation I will talk about the role of the Office of the Commonwealth Ombudsman. Then I’ll discuss some of the trends in complaints that we’re seeing. 

      And I’ll finish up with an early look at our investigation into complaint handling by Australian and ACT government agencies. 

      The Ombudsman’s role 

      Ombudsman institutions have been around in Australia for almost 40 years, handling complaints about every tier of government – federal, state, territory and local. 

      More recently we have seen the emergence of a range of industry Ombudsmen schemes handling complaints about firms operating in particular industries. 

      The number of matters handled by Ombudsmen each year is impressive. 

      For example, each year our office will receive around 23,000 approaches (that is, people approaching us to complain) from individuals, groups or organisations, and we will formally investigate several thousand of them. 

      The issues raised with us range from the simple to the complex, across all the activities of government – a decision delayed, a letter that can’t be understood, a benefit wrongly withheld, a visa denied, lost records, and alleged corruption are some examples. 

      The notion is now embedded that people have a right to complain about government, without hindrance or reprisal, and to have their complaint resolved on its merits. 

      But of course ombudsmen don’t exist in a vacuum. Most people’s interaction with government won’t be with an ombudsman, but rather with the agency that is providing them with a service. 

      That means the first opportunity to deal with a complaint is in the hands of the agency. This is, of course, as it should be. 

      But agencies’ willingness to engage with, resolve and seek to learn from complaints is a feature of the public sector landscape that differs from the landscape when ombudsman offices were set up.

      And that make the relationships between agencies and ombudsmen, and ombudsmen and citizens, different from what they once were. 

      It’s best summed up by the idea that agencies deal with complaints, while ombudsmen deal with disputes. 

      Agencies are the first to receive and seek to deal with complaints. If the customer is not satisfied, they take their dispute with the agency to the Ombudsman. 

      That makes the Ombudsman very interested in agency complaint-handling systems. The better they work, the fewer disputes come through to us. 

      Where an agency has a complaint-handling process that is well publicised, our office is less likely to receive direct complaints about that agency. 

      When complaints are directed to the agency in the first instance they are, in most cases, resolved in a relatively timely and cost-effective manner. 

      The agency’s relationship with the complainant is improved as a result of the interaction, and the complaint provides the learning that can be incorporated into the agency’s systems through continuous improvement. 

      To this end, we often help agencies develop service charters and effective complaint handling systems. This is an important investment for us because we see the results when things go wrong. 

      If a dispute does come to us, we may investigate it with an emphasis on speedy resolution and an eye to ensuring systemic improvement to public administration generally. 

      Most investigations are conducted informally, but more complex investigations may require the review of many files and documents, formal interviews and independent specialist advice. 

      The Commonwealth Ombudsman may also choose to use his ‘own motion’ power to initiate an investigation. This often follows receipt of several complaints about the same issue, indicating a recurring problem. 

      We have almost completed an own motion investigation into Commonwealth agency complaint handling. I’ll elaborate on that in a few moments. 

      Trends in complaints and what does the future hold 

      But first I’d like to talk a little about the trends we’ve been seeing in complaints across government.

      In the financial year to the end of April, within-jurisdiction approaches to our office were down 5 per cent (to 15,097).

      But that’s an average. Complaints about some agencies in our jurisdiction are falling, while others have increased. I’ll expand on some of those areas. 

      • ATO – In the past couple of years, the Tax Office has made a number of improvements to its complaint handling, and we have seen a reduction in the number of complaints we receive as a result. In 2012-13, the number of complaints decreased by more than 34 per cent from the previous year. So far this year Tax Office complaints are down by another 27 per cent. The ATO and our office have done a lot of good work over the past couple of years and that is paying dividends. 
      • Child Support Agency – This agency continues to receive consistently fewer complaints. Since bedding down reforms to the Child Support Scheme that were introduced in 2008, CSA has been able to maintain a downwards trend in complaint numbers. 
      • Australia Post – Complaints about Australia Post are up by approximately 10 per cent compared to the same period last year. The most common complaint issues relate to delivery issues. 
      • Immigration – There has been a slight increase in complaints about the Department of Immigration and Border Protection beginning last October, which correlates with the application of new border protection reforms. 
      • Overseas Students Ombudsman (OSO) – This is an interesting one. There has been a steady increase in approaches. This reflects an increase in the number of international students arriving in Australia, but also the number of students and providers using the OSO. Clearly our outreach strategies in raising awareness of the OSO and the right to complain are working. 
      Own motion into complaint handling

      Earlier I mentioned that we had almost completed an investigation into agency complaint handling. 

      We expect to publish the report of that investigation later this year, but I’d like to share with you some of the key points that have emerged so far. 

      The first thing to say is that our investigation confirms a conclusion we’d made based on anecdotal evidence: there is a very diverse approach in how agencies approach complaint handling – from the very good to the, well, not so good.

      And there certainly isn’t a one-size-fits-all approach that can be applied. 

      Our investigation has three main strands. 

      First, to describe the existing state of complaint management. This will then provide us with a benchmark into the future.

      Second, to analyse to see what is not working and why. This will allow us to identify high-risk areas and trigger points. 

      And third, to revise our Better Practice Guide, setting out the principles of good complaint handling and what an effective complaint handling system looks like and needs to have. 

      Current state of agency complaint handling 

      We asked about 150 government agencies to fill in a survey and received about a 65 per cent response rate, which we were very pleased with. 

      The result is the most comprehensive snapshot of Commonwealth complaint handling that has ever been done. 

      I should point out that our analysis of the survey results is mostly qualitative. Some organisations completed separate survey forms for different programs, which was very helpful, but that makes quantitative analysis less reliable.

      But there are some things we can say about complaint numbers. 

      It is clear that many factors influence raw complaint numbers so the number of complaints cannot, in itself, be an accurate indicator of agency performance. 

      Many factors that go towards improved performance, such as increasing the focus on complaints and rigour around recording them, can increase raw complaint numbers. 

      Equally, a reduction in numbers may be due to a change in responsibilities rather than an improvement in agency performance. 

      In some situations, the number of complaints did not necessarily increase, but centralised recording of all complaints became more widespread. 

      For example, the Department of Veterans’ Affairs created a specific Feedback Management Team in 2010, resulting in increased training and awareness of the complaints system across all DVA staff. 

      This greatly increased staff recording of complaints, with DVA reporting an eight-fold increase in complaint numbers from 2008-09 to 2009-10. 

      Another relevant factor is raising public awareness of either the organisation or the complaints mechanism. The Civil Aviation Safety Authority noticed an increase in complaints, and partially attributed it to an outreach program raising the profile of the Industry Complaints Commissioner.

      For smaller organisations, a single issue can result in a marked difference to their complaint numbers. The National Library reported that reduced parking was the main factor driving their complaint increase. 

      So, raw numbers tell us something but not the whole story. What else is important to think about when looking at complaint handling? 

      Quality. 

      We asked agencies whether they thought the quality of their complaint handling had improved or deteriorated. 

      Not surprisingly, no agency admitted to having worse complaint management than they did five years ago. In fact by far the biggest group thought the agency had improved markedly in the past five years.

      Even allowing for a bias towards positive self-reporting, this shows complaint management tends to be included in organisational continuous improvement.

      Fifty-seven agencies had had either internal or external reviews of their complaint system in the previous three years. This represents about two-thirds of the agencies that responded to our survey. 

      Agencies were asked what elements contributed to improved complaint management. 

      Improved processes was the most common reason. 

      This is consistent with our office’s view that good complaint management has many factors in common with good case management. 

      Clear and sensible processes support every aspect of complaint management, in particular efficiency, fairness and responsiveness. 

      But the second cause for improvement was less expected; not because it isn’t important but because we didn’t think it happened that much: senior leadership support. 

      Senior leadership support is vital for organisational changes, particularly cultural changes such as creating or fostering a culture that values complaints.

      In our survey we specifically asked who the senior management owner of the complaints process was. Fifteen responses nominated the Chief Executive Officer or Commissioner, 58 indicated a Senior Executive Service level officer, and a further 10 stated it was a manager. 

      Even allowing for discrepancies in position titles, the responses show that complaints processes are commonly the responsibility of senior officers. 

      Agencies were also asked to list any other reasons for complaint management improvement that did not appear on the survey list. 

      The three most common additional reasons were:

      • incorporating complaints into everyone’s normal role 
      • publicising their complaint process 
      • regular detailed reporting to senior management. 

      Interestingly, increased resources was quite low on the list. This may be because no-one had actually received more resources, but it could also be because it is only one of the smaller factors in improving agency complaint management. 

      What did we find were the tricky bits for agencies? As you can imagine, there were several. 

      First point of contact resolution 

      We asked agencies whether they recorded expressions of dissatisfaction that were resolved at the first point of contact as complaints. 

      Of the 107 responses to this question, only 31 said that they recorded these contacts as complaints.

      Several organisations qualified their response by saying that it differed across the agency, or that complaints were recorded in some circumstances. 

      For example, the Global Feedback Unit in the Department of Immigration and Border Protection records these matters as complaints if they are received by the unit in the first instance. 

      However if the matters are received and resolved elsewhere in the department then they are not recorded as complaints. 

      Again, there is no right or wrong way to record first point of contact resolution, but the benefits of always recording these interactions are it: 

      • allows a complete picture of the work of the agency for budgeting and workforce planning purposes 
      • gathers the maximum possible complaint information for identification of areas for improvement 
      • allows identification of issues that may then be resolved through better public information, preventing work in the future 
      • emphasises the importance of front-line staff resolving enquiries or complaints wherever possible. 

      And the disadvantages? 

      • It takes time and resources. 
      • The person expressing dissatisfaction may not want the matter recorded and may be unwilling to give information. 

      Each agency needs to weigh the advantages and disadvantages. An important first step would be to find out how much first point of contact resolution takes place already. 

      It may be there’s a whole lot of effective complaint management going on that isn’t being taken into account. 

      Complaints handling by line areas vs designated complaints areas 

      We asked agencies if complaints were resolved to finalisation by the designated complaint handling area or by line areas in the organisation. 

      Allowing for differences of detail, the agencies fall into broad groups. Here’s a table that illustrates the point: 

      • Received and finalised by designated central area - 19 
      • Received and finalised by designated complaints personnel within line areas - 6 
      • Received and finalised by general personnel within line areas - 31 
      • Core business is resolving complaints - 6 
      • Received by central complaints area and finalised by line area - 10 

      There is no right or wrong way to manage complaints. The approach has to be fit for purpose for each individual agency. 

      But there are advantages and disadvantages to each model, and the correct model for each organisation will depend on a range of factors. 

      Generally, some things are easier or harder with each model (see below): 

       CentralisedLine area
      Consistent handling of complaintsEasierHarder
      Training staff in complaint management Easier Harder
      Accurate and complete record keepingEasierHarder
      Resolving problems at the first contactHarderEasier
      Providing a remedyHarderEasier
      Feeding complaint information to senior managementEasierHarder
      Integrating complaint information into changes to business practicesHarderEasier
      Dealing with complaints independently and without preconceptionsEasierHarder

      It is also possible to set up any type of hybrid model. For example, the Australian Federal Police operate a type of triage system depending on the subject matter or content of the complaint.

      Prior to legislative changes in 2006, the AFP dealt with all matters in a central area with the same degree of formality. This resulted in some delays for minor matters which could have been dealt with speedily by the line officers. 

      So now, less serious matters are dealt with by the line area where complaints raising more serious concerns are referred to the central area for investigation and resolution. 

      Organisations with discrete programs may also find that the benefits of centralisation are more than offset by the difficulty of training a centralised officer to be sufficiently knowledgeable about the organisation’s business. 

      For example, each program in the Bureau of Meteorology has its own system for handling and responding to complaints. 

      The bureau advises that “the diversity of products and services the bureau offers make it more efficient for the business area to respond”. 

      It is also relevant that the bureau gets very few complaints – one or two a month – meaning that carrying a complaint load is not an unreasonable burden for business areas.

      Referrals and transfers 

      An area of complaint management that is easy in theory, but challenging in practice, is the processes for referring matters to other organisations, and receiving matters that other organisations have referred. 

      The principle is quite straightforward; if one organisation receives a complaint that another organisation is best placed to resolve, then the matter should be transferred. In practice, this presents multiple challenges.

      First, determining and addressing the issues to be resolved. Members of the public do not always know which part of government is responsible for their problem and are not always clear about the different aspects of their complaint. 

      An important part of training for first point of contact complaint staff is how to disentangle the issues and translate the experience of the complainant into a structure and form that can be recognised by the bureaucracy. 

      Second, ensuring that any referrals or transfers comply with the legislative framework. 

      There are strict rules governing when a public sector body may disclose information about a person and these need to be reflected in agency policies. Often, consent of the complainant will be required. 

      Third, establishing upfront the ongoing responsibility for resolution, and communicating that to the complainant. 

      Complaints to our office that involve multiple organisations often include a complaint about a lack of communication from the first agency. 

      The first agency thought its obligation was discharged when the matter was transferred, but the complainant thought the agency would contact them again to finalise the matter. 

      We asked agencies whether they had a process for referring complaints to other organisations. Of the 107 responses to this question, 61 had a process, 36 did not, and 10 organisations said the question was not applicable to their work.

      The process of the Australian Customs Service is representative: 

      Where a complaint relates to the actions of another agency, the Complaints and Compliments Management Unit contacts the client to provide them with the contact details of the relevant agency. The complaint details are not provided to another agency directly, as it may contain personal information. 

      Another way of managing referrals out is to retain some degree of oversight of the resolution of the complaint. This is common within organisations – where a centralised complaint management area will refer a matter to a line area for resolution while retaining a general oversight role – but less so between organisations. 

      The Australian Rail Track Corporation oversights in some circumstances: 

      Complaints are received and logged in our system. If, following initial investigation, they are found to be the responsibility of a rail operator or another organisation, then they are referred by email to the appropriate person in that organisation for either a) a response to the complainant directly, or b) advice to ARTC so that ARTC can provide a response back to the complainant. 

      The main challenges that still exist 

      Most agencies we surveyed dealt with vulnerable people. 

      Vulnerable people have a higher propensity to need access to a complaints process because they are more likely to fall out of the machinery of public administration. 

      Problems with access, literacy, mobility and understanding lead to greater difficulty in accessing public services, or a greater likelihood of falling foul of regulatory authorities. 

      The natural tendency is for public sector organisations, with limited resources, to focus their attention towards the greatest good for the greatest number, with fewer resources devoted to those who are more problematic. 

      The role of a good complaint system is to act as a safety net, and put people safely back in the system with no loss of entitlement and with a minimum of stress to all concerned. 

      However, this process is made more difficult by the very attributes that make it more likely that people will have a complaint in the first place. 

      It is therefore critical that a complaint system places a great deal of emphasis on being accessible to vulnerable groups. 

      When dealing with people there must be some flexibility in the system to deal with those who fall towards the edges. 

      Our survey uncovered – or confirmed – three key aspects to providing flexible complainthandling systems. 

      First, you have to remove the barriers. Reaffirming the right of a client to complain, and making a public statement of your organisations’ commitment to that right, must be more than mere words. 

      One significant, if intangible, barrier to complaints is the preconception that it won’t make a difference; that nothing in government will ever change. 

      Emphasising openness, listening, trust and transparency can affect someone’s decision as to whether or not to attempt to fix their problem. 

      Presenting your complaint system in a way that is distant, formal and unsympathetic can in itself be a significant barrier to access. Feedback mechanisms should be easily and widely accessible. 

      The avenues of complaint and the information provided should be in simple language, available through a variety of mechanisms and widely understood. 

      These mechanisms should be approachable, simple and responsive to circumstances. 

      Second, make lots of channels available. In one good example from the survey, Australia Post allows complaints to be made directly onto its Facebook page, with staff providing a response in the same way. 

      Both the complaint and response are public, with anyone able to read the issues and replies. 

      For many people a Facebook page is a non-threatening and straightforward way of requesting advice or giving negative feedback, without the perceived formality of an email (let alone a letter), and the wait associated with a voice call to any large call centre. 

      Third, assist people through the process. Five organisations stated specifically that they took action to modify their complaint process to meet special needs. 

      This can be quite simple, for example the Australian National Preventative Health Agency advised that they may waive or change timeliness requirements in order to effectively deal with a complaint.

      Both the Australian Taxation Office and the Office of the Registrar of Indigenous Corporations advised that they can meet complainants face to face if necessary, at a location convenient to the complainant, and outside their offices where required. 

      Many organisations also have specific policies that govern their dealings with vulnerable groups in all circumstances, including during the complaint process. For example, the Australian Federal Police has comprehensive policies on how they interact with young people. 

      Finally, and perhaps most importantly, building a culture that supports complaints. 

      One of the main influences on best practice complaint handling is fostering a culture that values complaints. 

      Good complaint management requires individual staff members to see complaints as valuable and to know that dealing well with complaints is an important part of their job. 

      We asked agencies, firstly, if they fostered a culture that values complaints. Ninety-three agencies replied that they did, six replied that they did not. We asked agencies to describe the ways they fostered a culture that values complaints. The most common response was that their organisation treated complaints as a valuable source of information for continuous improvement. 

      This view – that complaints are useful to an organisation – is now almost universally accepted. However, this is a change in attitude in the Australian Public Service over the past 20 years. 

      In our first Good Practice Guide to Effective Complaint Handling, published in 1997, the then Government had just announced that public sector agencies would, for the first time, be required to have customer service charters. 

      Our guide started with a chapter on client service in the public sector and needed to state: 

      The importance of good client service in the public sector is often overshadowed by the need to cut costs and do more with less. Unfortunately, good client service is sometimes considered a luxury that the public service cannot afford.i

      From the responses we received in the survey, it seems that agencies no longer believe that good client service is a luxury, even though it may not be achieved to a high enough standard enough of the time. 

      Other ways in which agencies fostered a culture that values complaints included regular training for staff, internal communication reinforcing the value of complaints, strong support from senior management, and by emphasising complaint processes during the induction of new officers. 

      Conclusion 

      So what would I like you to take away from today? 

      First, the importance of complaint handling. I think I’m preaching to the converted on that point, but it is always worth making. 

      Complaints are a tremendous source of intelligence – they have real business value and those who deal with complaints and complainants have real value within their organisations. 

      Second, there’s no one-size-fits-all solution to dealing with complaints. Every organisation needs to work out what is going to be fit for purpose. 

      But in doing that, we know some things that make organisations more likely to succeed than to fail. For example: 

      • culture counts – are you interested in complaints or not? 
      • measurement counts – it’s human nature to value what we can measure, but we have to be a bit sophisticated about what we measure. Raw complaint numbers aren’t enough 
      • senior leadership commitment counts – hostility or even just ambivalence towards complaint handling at the top will hold an organisation back 
      • how first contact with complainants is managed counts – do you have ways of assisting the vulnerable? Are you resolving issues at the earliest point in the process, before they escalate? 

      These are things we know intuitively, but our investigation into agency complaint handling is providing evidence that we are right. 

      I’m hopeful we’ll find out more as the investigation continues and I look forward to sharing that with you shortly with the release of our report. 

      But for now I’d like to thank you for listening and wish you all well for the remainder of the conference. 

      Thank you. 

      i A Good Practice Guide for Effective Complaint Handling 1999 reprint