DELIVER

The complaint process is a journey for both the complainant and the complaint handler.

In some cases, a person's experience with the complaint handling process can be as important for their satisfaction as the final outcome.

There are eight steps to deliver a high quality complaints service:

  1. Identify and log the complaint

  2. Acknowledge the complaint

  3. Assess and triage

  4. Resolve early or investigate

  5. Consider potential remedies

  6. Communicate the outcome

  7. Finalise or escalate

  8. Feedback systemic issues.

Complaints likely to exceed expected timeframes will also need a discrete 'update' step to keep the complainant informed of progress.

For straightforward complaints, a frontline complaint handler may take all these steps in concert as they may log, acknowledge, assess, resolve, offer a remedy, communicate the outcome and finalise the complaint in a single phone call.

Step 1—Identify and log the complaint

The first step is to work out whether the person is making a complaint.

This means working out:

  • are they are dissatisfied with your agency? For example with its services, actions, decisions, inaction, delay, policy or processes?

  • do they expect a response, or should one be provided?

Is the person dissatisfied?

Many people will make it clear they are dissatisfied. However, some people cannot clearly express their dissatisfaction.

If it's not obvious that the person wants to complain, consider if there is an 'implied' complaint.

You will need to ask questions and assess context to work out if the dissatisfaction is implied. This may involve looking at records of previous interactions with your agency.

Case study: John has an intellectual disability. In March, he starts ringing regularly ask for a print-out of the services he received from your agency. At the third request, a service officer looks at John's record and sees this type of contact was unusual before March. She asks John why he needs the printout. John says the lady who provides his in-home services has stopped coming. The service officer identifies an implied complaint about in home services.

What are they dissatisfied about?

You will need to work out if the dissatisfaction is about your agency's services, actions, decisions, inaction, delay, policy or processes.

If they are dissatisfied with another agency or entity, your agency should assist them to find the right complaint pathway.

Do they expect a response (or should one reasonably be provided)?

Ask the person whether they want a complaint handler to respond to their concerns. If the answer is yes, you have identified a complaint.

If the person answers no, be alert to the possibility that the person is confused or afraid to say they want to complain.

You should encourage complaints. If the person seems unaware, confused or afraid of the complaints process you can explain:

  • complaints are welcome

  • there is no retribution for complaining

  • complaints can be anonymous

  • the steps in your complaints process.

Some cultures do not encourage complaining and certain languages do not have a word for 'complaint'. Some people will have difficulty explaining what they are complaining about and others might not understand what a complaint is.

Log the complaint

Once you have identified a complaint, log it in your complaint handling system immediately.

Record any accessibility needs

Ask questions to work out if the person has particular accessibility needs and record these. For example, be sure to record:

  • interpreter needs, such as Telephone Interpreter Service, AUSLAN or Indigenous Language Interpreter

  • communication needs and preferences, for example contact in writing or by phone, larger fonts or alternative electronic formats, publications in other languages

  • if the person needs or asks for another person's involvement, such as assistance from a nominee or other person such as a friend, family member or caseworker (consent may be required).

Step 2—Acknowledge the complaint

Prompt acknowledgement of a complaint reduces the risk of dissatisfaction later in the process. It can help the complainant understand the process and help you manage their expectations.

What should an acknowledgement include?

A good acknowledgement will:

  • explain the complaint process

  • give contact details and preferably the name of a contact person

  • indicate how and when to provide any further information

  • explain how long it is likely to take to:

    • contact the complainant again

    • resolve the complaint

  • provide a complaint identification number.

How should a complaint be acknowledged?

Where possible, try to acknowledge the complaint in the medium it is received or the complainant prefers.

Written acknowledgement can be beneficial but is not always necessary. It can be more efficient to acknowledge complaints verbally.

Telephone acknowledgement can be provided at the same time as the complaint outcome is explained if the complaint can be finalised promptly.

Always acknowledge by phone if the complainant says they prefer not to receive written correspondence, or would be unable to read or understand it.

It is good practice to acknowledge in writing if the complainant prefers or is likely to benefit from written correspondence (for example, if the matter is complex).

Written acknowledgement can be suitable for automation, which can ensure high quality acknowledgements are provided consistently.

However the complaint is acknowledged and t is an opportunity to explain the process, and what can and cannot be done to manage the complainant's expectations early.

Step 3—Assess and Triage

A good initial assessment helps you decide what action is required—including where to direct it and whether it needs to be prioritised.

Be familiar with your agency's guidelines on:

  • what information to obtain and consider when conducting an initial assessment

  • workflows for complaint referral and allocation

  • which complaints should be prioritised.

Ask the person what outcome they are seeking. Understanding this will help you manage their expectations and work out whether it is suitable for early resolution or investigation.

Why prioritise a complaint?

The main reason to give a complaint priority is because something about it is urgent. What is urgent will differ depending on the agency business.

Some examples include where there are:

  • urgent wellbeing, health or safety implications for the person involved, or the public at large

  • time limits for achieving a practical outcome

  • risks of escalation unless actioned promptly.

In other instances, the sensitivities of the complaint may call for special handling. For example, if there is a risk to the agency or its reputation.

Questions to think about:

  • Is contact needed to clarify what the complaint is about or what outcome they are seeking?

  • Is the complaint about something your agency is responsible for or can help with?

  • Is the outcome they want achievable? Is contact needed to manage their expectations?

  • Is the complaint simple or complex?

  • Are there multiple complaint issues that need to be separately addressed?

  • Is the complaint likely to require formal investigation, or might the complaint be resolved through explanation or discussion?

  • Should the complaint be prioritised?

  • Does the complainant have particular accessibility needs?

  • Are there potential systemic issues or administrative errors in the complaint?

  • Does the complainant need a referral or help to reach a more appropriate body for dealing with some or all of their issues?

Step 4—Resolve Early or Investigate

Some complaints can be resolved on first contact, or with minimal further assessment or enquiries being made. Other complaints will require a more formal investigation before it can be resolved.

What does ‘resolved’ mean

Resolved means providing the complainant with a fair and reasonable response in the circumstances.

It generally means you have either provided the outcome sought by the complainant or if that is not possible, you have:

  • accurately identified and assessed the key issues

  • treated the person with respect and fairness

  • provided an appropriate explanation, remedy or referral.

To resolve early you need to:

  • have a clear understanding of the key issues and outcome being sought

  • have sufficient information and delegation to make a sound decision

  • be able to provide a prompt, fair and reasonable response to the complainant.

You will also need to understand any legislative requirements, agency responsibilities and powers, relevant internal procedures and policies, and may need access to primary documents. If this information cannot be obtained quickly, a more formal investigation may be appropriate.

Simple or routine complaints are most suitable for quick resolution. For example, complaints that:

  • are outside your jurisdiction and can be resolved by a suitable referral

  • can be resolved by providing a better explanation or information

  • relate to simple errors that can be readily fixed

  • seek an impossible or unreasonable outcome.

Referral

If a complaint falls outside your agency's area of responsibility, you should try to help the person find the right complaint pathway.

Be aware that people can get stuck, frustrated or lost on the 'referral roundabout'. You should try to practice a 'no wrong door' approach.

If a person is not vulnerable, give them a phone number or email for the pathway they need.

Vulnerable complainants may need additional assistance, such as an assisted referral, to reach complaint handlers in another agency.

Investigation

If the complaint cannot be resolved early, an investigation may be required.

Investigation plans can be as simple as a few dot points to outline proposed actions. They can provide a useful supervision checkpoint and reduce the risk of:

  • overlooking or forgetting a key aspect of the complaint during the investigation

  • the investigation becoming unnecessarily slow or unfocused.

Investigation plans may not be needed for simple or routine complaints, but they are important for more complex investigations, such as where further information from the complainant or third parties will be sought. They also ensure continuity and efficiency when complaints are transferred or reassigned.

Planning

Your investigation plan should include:

  • key complaint issues, questions to be answered and information to be collected

  • the estimated timeframe for completion

  • the outcome sought and any steps needed to manage expectations

  • potential outcomes and remedies

  • any special considerations (for example, if the person has asked for their identity to be withheld from others or if there is sensitive information).

Revisit the plan and make adjustments as circumstances change and new information becomes available.

The scope of your investigation should be proportionate taking into account factors such as complexity, seriousness and any statutory requirements.

Process

Early resolution and investigation processes must be impartial, confidential, transparent and fair.

Base your findings on relevant evidence that is logically capable of supporting your decision (not on guesswork, preconceptions, suspicion or questionable assumptions).

Keep written records of oral information you receive and reasons for your findings and decisions.

You can ask people to provide information or documents, but remember—complainants do not have to substantiate every fact or element in their complaint and you can use reliable information from any source.

Tip: Although some complaints require written information and documents, it is important not to make this a barrier. Complaints can often be quickly resolved verbally.

Give complainants an opportunity to respond to contrary information or evidence before making a final decision.

Timeliness and updates

If it appears unlikely that you will meet the timeframes for resolution in your agency's guidelines, or a timeframe previously provided to a complainant, a record should be made, and an update provided to the complainant.

Providing updates will help manage expectations and can often avoid further complaints about delay and unnecessary escalation.

Supervisors and managers should monitor complaints that are not meeting timeframes—sometimes a complaint may need to be escalated to a more senior officer, especially if it is more complex than first thought.

Step 5—Consider potential remedies

The best remedies are proportionate, fair and provided in a timely fashion.

While remedies generally follow early resolution or investigation, it is useful to think about offering potential remedies at all stages, including acknowledgement, assessment, and investigation.

What kind of remedies can you provide?

Think creatively about the remedies you could offer. There are many different kinds of remedies, including

  • listening to and acknowledging the person's experience

  • apologising

  • expediting an action

  • changing a decision or agency process

  • providing a better explanation

  • removing a penalty or providing financial compensation.

Where possible, outcomes should be tailored to the underlying cause of each complaint.

Tip: Think about how the complainant may perceive the actions that have been taken. For many people, having their concerns acknowledged by a respectful complaint handler will form an important part of the remedy.

Collaborative Complaint Resolution (CCR)

Some agencies may wish to consider whether, for serious, systemic or difficult complaints, a meeting between the agency and the complainant could facilitate a better outcome. Such a meeting could be held with or without a third party facilitator.

This is not a requirement for good complaint handling (unless there is a legislative schemes mandating use of Alternative Dispute Resolution processes such as mediation or conciliation) but may be a useful tool if it can be done fairly and efficiently.

For example, it may be helpful to have a meeting between the complainant and relevant parties to the complaint such as where the issue:

  • is complex and involves more than one agency or a contracted service provider

  • is amenable to a negotiated outcome.

Benefits of CCR: CCR can be relatively informal, flexible and empowering for the complainant. It is outcome focused, and can assist in maintaining and repairing relationships. It can be relatively inexpensive if it prevents future costs, for example due to repeat contact, escalation or reputational damage.

Risks of CCR: If not done properly it can maintain or amplify the power imbalance and can be resource intensive compared to traditional complaint handling. It is not appropriate when the complaint involves potential systemic problems, public interest questions or allegations of abuse of power, corruption, or criminal conduct.

If considering CCR take care to:

  • explain the process to the complainant

  • ensure the complainant has voluntarily agreed to participate in the process

  • invite the complainant to bring a support person

  • where possible have an independent facilitator present.

In some cases, it may help to appoint a person who has not handled, or is not connected, to the complaint to assist the complainant. Sometimes responsibility will be spread across multiple areas of the organisation or multiple organisations.

Step 6—Communicate the outcome

Once you are in a position to resolve the complaint you must communicate the outcome and reasons for your decisions. If an outcome is unfavourable you should also provide options for escalation or review.

Good communication is important for ensuring procedural fairness. It also:

  • improves complainant satisfaction

  • decreases the risk of unnecessary escalation.

It is important for transparency which encourages better quality decisions and increases trust in your agency.

Communicate intended outcomes

It is a good idea to discuss the intended outcome of an investigation with a person before finalising their complaint.

The outcome should be explained in a way that provides sensible and clear reasons about why the complaint is about to be finalised.

This gives you an opportunity to explain why you have reached the decision you have and gives the complainant a chance to let you know if you missed any important issues or information. You can reduce the likelihood of the further escalation by giving the person a good explanation and a chance to be heard at this stage.

Choose the best way to communicate

Your agency should have guidance about how to communicate particular outcomes. As a general rule, outcomes can be provided in writing, verbally or both.

The most important thing is to make sure you communicate the outcome in language and a form that the complainant will be able to access and understand. Make sure you consider the circumstances of the complainant and any special communication needs or preferences they have.

If the complaint is serious, complex or disputed, it may be more suitable to respond in writing (or both by phone and in writing).

What to include

When communicating outcomes, you should include:

  • a short summary of what the complaint was about

  • what actions were taken to assess and/or investigate each element of the complaint

  • what information and evidence you considered

  • reasons for any decisions, findings or conclusions

  • any remedial action.

It is a good idea to acknowledge the complainant's contribution and their perspective about their experience and how the issues raised may affect them (even if you cannot change or fix them).

Outcomes advised in writing should:

  • invite the person to make contact if they want to discuss the decision

  • provide a contact name and contact details for the decision-maker

  • include advice on internal and external review options (especially if the outcome is not fully favourable).

Outcomes advised by telephone should provide internal and external review options if the person implies or expressly states that they are unhappy with the outcome.

Make it timely

Outcome decisions should be communicated to the complainant as soon practical after the decision is made.

Step 7—Finalise

Finalising complaints

A complainant does not have to be satisfied for a complaint to be closed. However, you should not finalise a complaint until an outcome has been provided and any quality assurance checks are satisfied.

The complainant should be invited to contact your agency again if they have questions or are dissatisfied with the outcome of their complaint. Don't take it personally if they contact to say they want a better explanation or are dissatisfied with the handling or outcome of their complaint.

The best complaint handlers recognise this is a normal and important part of complaint handling. They proactively invite people to access review and escalation options if they seem dissatisfied.

Person is confused or has further questions

In most cases, the person who handled the complaint can provide a further explanation. Sometimes you may just need to repeat your explanation, and other times you may need to find a new way to explain it.

It can be helpful to switch to a new mode of communication. For example, if a person is struggling to understand a verbal explanation, you could offer to also provide an explanation in writing. Similarly, it may help to call someone to explain an outcome if they are confused by a written explanation.

Where evidence was scant, inconclusive or evenly balanced, this should be explained.

Person is dissatisfied with outcome

Your agency should have guidelines for escalating complaints.

It is generally fine for you as the original decision maker to reconsider your own decisions if a complainant says they are dissatisfied. This is an efficient way to fix up any obvious problems quickly and efficiently.

However, you should escalate the complaint if your reconsideration result is unfavourable to the complainant. Escalated complaints should then be handled by another staff member in accordance with your agency's escalation guidelines.

Person is dissatisfied with handling of complaint

If the complaint is about complaint handling processes, consider whether process was followed. If it wasn't, look at why not, whether it affected the outcome, whether a remedy should be provided and whether internal feedback is required.

Update your records

Before you finalise a complaint it is good to check that all conversations, steps, decisions and reasons have been properly recorded. You should also check that complaint data fields are up to date with any information that has been collected during the complaint process.

The best way to be sure that a person is satisfied with a better explanation (and does not wish to pursue a review further) is to ask again at the end of the conversation if they would like further review.

Step 8—Feedback systemic issues

The final step is to consider whether the complaint raised any systemic issues that should be fed back to a supervisor or other areas of your agency.

Make sure you are familiar with your agency's processes for recording and reporting systemic issues.

Identifying systemic issues

Systemic issues are problems in the administration of government programs that are likely to affect a larger group of people, not just the individual complaining.

One off mistakes and errors by agency staff are not generally systemic issues, unless they point to a broader training, supervision or quality assurance issue.

Examples of common systemic issues

Individual complaints can often throw up systemic issues such as:

  • problems with record keeping

  • broader training and support needs where a number of staff have made mistakes or given inaccurate information

  • delays and bottlenecks caused by issues such as poor communication or integration

  • inconsistencies between internal procedures and legislative obligations

  • lack of clarity in internal policies and procedural guidance

  • gaps where people or work 'falls through the cracks', for example due to inadequate delineation of responsibilities.

Systemic issues beyond your agency's control

Systemic issues can also arise in legislation and government policy that is beyond the scope of your agency's administrative responsibility.

You should record this information so that it can be captured in your agency's complaint data and shared with government as appropriate. Bring it to your supervisor's attention if it relates to a new or changing program.

Complaint handlers are a critical conduit for systemic issues because they gather frontline feedback and can forward this to the responsible business area.