Feedback and Complaints Management Policy and Procedure

NDIS Policies and Procedures Manual – Core Module

Document Number: CM-POL-010

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Legal Name: Holistic Healthcare Management Services
ABN: 20695058096
ACN: 695058096
Primary address/head office: 15 Agasse Way, Tapping WA 6065
Document Name: NDIS Policies and Procedures Manual – Core Module
Document Number: CM-POL-010
Approved by: Director
Date Approved: February 2026
Version No: 1.0
Comments: Initial Release of the Policies and Procedures Manual
Next Review Date: May 2026

Introduction and Purpose

Holistic Healthcare Management Services is committed to fostering a culture that encourages and welcomes feedback and complaints as essential tools for continuous improvement in the delivery of supports and services. This policy ensures that complaints and feedback are managed respectfully, effectively, and in compliance with the National Disability Insurance Scheme (Complaints Management and Resolution) Rules 2018, while adhering to principles of procedural fairness and natural justice (Indicator 1)[cite: 1].

The purpose of this policy is to establish a transparent, accessible, and supportive system for managing complaints and feedback, ensuring participants and stakeholders feel valued and heard. This includes enabling external advocacy and empowering participants to express their concerns without fear of retribution (Indicator 2)[cite: 1].

The policy aims to support continuous improvement by using complaints and feedback to identify gaps, enhance service delivery, and maintain high-quality supports that meet participant needs and expectations (Indicator 3)[cite: 1].

Scope

This policy applies to all aspects of Holistic Healthcare Management Services’s operations, including[cite: 1]:

  • Participant interactions and support delivery[cite: 1].
  • Communication with stakeholders, such as families, advocates, and external agencies[cite: 1].
  • Internal operations, such as governance and staff performance[cite: 1].

It covers feedback and complaints received from[cite: 1]:

  • Participants[cite: 1].
  • Families, carers, or advocates[cite: 1].
  • Workers or contractors[cite: 1].
  • Any other relevant stakeholders[cite: 1].

This policy is relevant across all service settings, including residential, community-based, and administrative environments[cite: 1].

Definition

Term Description
Complaint An expression of dissatisfaction regarding any aspect of the provider’s services, supports, or operations, made by a participant, stakeholder, or worker[cite: 1].
Feedback Comments, suggestions, or opinions provided by participants or stakeholders regarding the provider’s services, supports, or operations, whether positive or negative[cite: 1].
Procedural Fairness A principle ensuring all parties involved in a complaint are treated equitably, with an opportunity to be heard and decisions made based on objective evidence[cite: 1].
Natural Justice The right to a fair process, including unbiased decision-making and timely resolution of complaints[cite: 1].
Advocate A person or organisation supporting a participant to express their views or pursue complaints, ensuring their rights and interests are represented[cite: 1].
External Avenues for Complaints Agencies or bodies outside the organisation, such as the NDIS Quality and Safeguards Commission, that participants can approach if dissatisfied with internal complaint resolution[cite: 1].

Outcomes and Indicators

Term Description
Each participant has knowledge of and access to the provider’s complaints management and resolution system. Complaints and other feedback made by all parties are welcomed, acknowledged, respected and well-managed.
  • A complaints management and resolution system is maintained that is relevant and proportionate to the scope and complexity of supports delivered and the size and scale of the organisation. The system follows principles of procedural fairness and natural justice and complies with the requirements under the National Disability Insurance Scheme (Complaints Management and Resolution) Rules 2018[cite: 1].
  • Each participant is provided with information on how to give feedback or make a complaint, including avenues external to the provider, and their right to access advocates. There is a supportive environment for any person who provides feedback and/or makes complaints[cite: 1].
  • Demonstrated continuous improvement in complaints and feedback management by regular review of complaint and feedback policies and procedures, seeking of participant views on the accessibility of the complaints management and resolution system, and incorporation of feedback throughout the provider’s organisation[cite: 1].
  • All workers are aware of, trained in, and comply with the required procedures in relation to complaints handling[cite: 1].

Guiding Principles

  • Accessibility: Feedback and complaints mechanisms are easily accessible to all participants, with information provided in formats and languages suitable for their needs (Indicator 2)[cite: 1].
  • Respect and Support: Participants and stakeholders are encouraged to provide feedback or make complaints without fear of reprisal. Their concerns are acknowledged and addressed respectfully and promptly (Indicator 1)[cite: 1].
  • Transparency: The complaints management system is transparent, with clear processes for lodging, handling, and resolving complaints, including external avenues for escalation (Indicator 2)[cite: 1].
  • Continuous Improvement: Feedback and complaints are seen as opportunities to identify areas for improvement and inform organisational development (Indicator 3)[cite: 1].
  • Compliance: The system aligns with relevant legislation, including the NDIS Complaints Management and Resolution Rules 2018, ensuring compliance and procedural fairness (Indicator 1)[cite: 1].

Complaints Management Process

A structured complaints management process ensures that all concerns are handled fairly, transparently, and in a timely manner. The following key steps outline how Holistic Healthcare Management Services manages complaints to maintain high-quality services and safeguard participant rights[cite: 1]:

1. Receiving the Complaint

Complaints can be submitted through various channels, including face-to-face discussions, written communication, phone calls, emails, and online forms. Holistic Healthcare Management Services ensures that all participants, carers, and other stakeholders can provide feedback in a way that suits their needs, including offering assistance through interpreters, Easy English documents, and alternative communication tools. Staff members must document all complaints accurately, ensuring that key details such as the nature of the complaint, the participant’s concerns, and any preferred outcomes are recorded[cite: 1].

2. Acknowledging the Complaint

Upon receiving a complaint, Holistic Healthcare Management Services provides written acknowledgment within two business days. This response confirms receipt of the complaint and outlines the steps in the resolution process, expected timelines, and contact details for the person managing the complaint. Participants are also informed of their rights, including their right to seek advocacy support. This early engagement reassures participants that their concerns are taken seriously and will be addressed in a fair and timely manner[cite: 1].

3. Assessing the Complaint

Each complaint is assessed to determine its severity, urgency, and the most appropriate response. Complaints that involve serious allegations—such as abuse, neglect, or safety concerns—are escalated immediately to senior management and relevant authorities, in line with legal and regulatory obligations. Less critical complaints are assigned to the appropriate staff member for investigation. Risk assessments may also be conducted to ensure that any immediate threats to participant safety are promptly addressed[cite: 1].

4. Investigating the Complaint

A fair and impartial investigation process is undertaken to gather relevant facts and perspectives. This may include reviewing records, speaking with the complainant and other involved parties, consulting policies and procedures, and, where necessary, seeking expert advice. Investigations must be conducted in a manner that upholds privacy and confidentiality, ensuring that all parties are treated with respect and procedural fairness[cite: 1].

5. Resolving the Complaint

Once the investigation is complete, a resolution is determined, and appropriate actions are taken. If the complaint is upheld, corrective measures—such as changes to policies, additional staff training, or process improvements—are implemented. If the complaint is not upheld, the participant is provided with a clear explanation and information on further options. All resolution outcomes are communicated to the complainant in writing, detailing the steps taken and any improvements resulting from the complaint[cite: 1].

6. Providing Updates and Follow-Up

For complex complaints that require extended investigation periods, participants receive regular updates on progress. Once the complaint has been resolved, follow-up actions may be taken to ensure the participant is satisfied with the outcome. Ongoing monitoring helps to identify any systemic issues and ensures that lessons learned from complaints contribute to continuous improvement[cite: 1].

7. Escalation and External Review

If a participant is dissatisfied with the internal resolution process, they are guided on how to escalate their complaint to external bodies. This may include lodging a complaint with the NDIS Quality and Safeguards Commission via phone at 1800 035 544, online at www.ndiscommission.gov.au, or by email at contactcentre@ndiscommission.gov.au. Participants may also be referred to state-based ombudsman services, disability advocacy groups, or legal aid services for further assistance. Staff assist in this process by providing contact details, explaining available options, and supporting the preparation of any required documentation[cite: 1].

8. Documentation and Continuous Improvement

All complaints, their investigation processes, and resolutions are recorded in the complaints register, ensuring compliance with record-keeping requirements. Complaint data is regularly reviewed to identify trends, improve service delivery, and prevent recurring issues. Findings from complaints management processes inform staff training, policy updates, and quality improvement initiatives[cite: 1].

Policy

Complaints Management System

Holistic Healthcare Management Services will establish and maintain a robust complaints management and resolution system that is designed to be both comprehensive and proportional to the size, scope, and complexity of the supports delivered. This system will clearly outline the processes for receiving, lodging, acknowledging, investigating, and resolving complaints. Procedural fairness and natural justice principles will underpin all aspects of the system to ensure that all parties involved are treated equitably and respectfully. The system will comply fully with relevant legislation, including the NDIS Complaints Management and Resolution Rules 2018, ensuring that participants and stakeholders are supported through a process that is transparent, accessible, and legally sound (Indicator 1). By addressing complaints effectively, the organisation commits to building trust and fostering an environment where feedback is not only welcomed but actively sought as a critical tool for improvement[cite: 1].

Participant Information and Advocacy

Participants will be provided with detailed and accessible information about how to give feedback or lodge a complaint. This will include written and verbal explanations in plain language, as well as alternative communication modes tailored to participants with specific needs, such as those with hearing or visual impairments or from diverse linguistic backgrounds. Participants will also be informed about their right to access advocacy services, including independent advocates, to support them through the complaints process. Staff will proactively provide information about external complaints mechanisms, such as the NDIS Quality and Safeguards Commission, ensuring participants are fully aware of their rights and avenues for escalation. The organisation is committed to creating a supportive and inclusive environment where participants feel safe and empowered to voice their concerns without fear of reprisal or judgment (Indicator 2)[cite: 1].

Worker Training and Awareness

All workers will be trained comprehensively on the organisation’s complaints management system, with a focus on their roles and responsibilities in facilitating feedback, resolving complaints, and adhering to procedural fairness. Training sessions will include practical exercises to build empathy, improve communication skills, and equip workers with the tools to handle complaints sensitively and professionally. Workers are expected to create an environment of mutual respect and trust, ensuring that participants feel confident in expressing their concerns. By fostering a positive culture around complaints, workers can transform challenges into opportunities for organisational and individual growth. Periodic refresher training and competency assessments will ensure workers remain updated on policies, best practices, and legal requirements (Indicator 4)[cite: 1].

Continuous Improvement

Holistic Healthcare Management Services is committed to using complaints and feedback as a foundation for continuous improvement. This commitment will be achieved through regular reviews of the complaints management system, incorporating participant feedback and adhering to best practices to enhance its accessibility and effectiveness. Trends and patterns identified through complaints data will be analysed to pinpoint systemic issues or areas requiring development. Outcomes from complaints will directly inform updates to organisational policies, service delivery models, and worker training programs. This iterative process ensures the organisation remains responsive to participant needs and regulatory requirements, continuously striving to deliver high-quality supports (Indicator 3)[cite: 1].

Procedure

Receiving Feedback and Complaints

Holistic Healthcare Management Services is committed to creating a culture where participants, families, carers, and other stakeholders feel comfortable providing feedback or lodging complaints. Feedback can be given through multiple channels, including in-person discussions, written submissions, phone calls, emails, or online forms. Recognising that participants may have diverse communication needs, Holistic Healthcare Management Services ensures that all feedback mechanisms are accessible and inclusive. Alternative communication methods, such as interpreters, Easy English documents, and assistive technology, will be provided as needed to support participants with language barriers, literacy challenges, or physical disabilities. When a complaint is received, the staff member handling it must document all relevant details, including the participant’s concerns, the nature of the issue, and their preferred resolution outcome. If a complaint is made verbally, staff will assist participants in formalising their concerns to ensure accuracy and clarity. Confidentiality is a core principle of the complaints process, and all complaints, whether identified or submitted anonymously, will be treated with equal seriousness and a commitment to resolution. Complaints received anonymously will still be investigated where possible, and necessary action will be taken to address systemic issues that may be raised. Staff will reassure participants that raising a complaint will not result in negative consequences and that their concerns will be handled with professionalism and respect[cite: 1].

Acknowledging Complaints

Once a complaint is received, Holistic Healthcare Management Services will provide a written acknowledgment to the participant within two business days. This acknowledgment serves to confirm receipt of the complaint and reassure the participant that their concerns are being taken seriously. The response will include details about the complaints handling process, an estimated timeframe for resolution, and the contact details of the staff member responsible for managing the complaint. Participants will also be provided with information about their rights throughout the complaints process, including their right to seek independent advocacy services if needed. Where appropriate, referrals will be made to advocacy organisations that can support participants in navigating the complaint resolution process. This approach ensures that participants remain informed, empowered, and engaged in the resolution of their concerns. Transparent communication is key to fostering trust, and Holistic Healthcare Management Services remains committed to keeping participants updated at every stage of the process[cite: 1].

Investigation and Resolution

Every complaint lodged with Holistic Healthcare Management Services will be investigated thoroughly, impartially, and in a timely manner. Investigations will be guided by the principles of fairness, respect, and natural justice, ensuring that all parties involved have an opportunity to be heard. The investigation process will involve collecting all relevant information, including participant statements, incident reports, witness accounts, and any supporting documentation. If required, consultations with internal stakeholders or external subject matter experts may be conducted to ensure a comprehensive understanding of the issue. Once the investigation is completed, a resolution outcome will be determined, and the participant will be provided with a clear explanation of the findings. Where the complaint is upheld, corrective actions will be implemented to address the concerns raised and prevent recurrence. If the complaint is not upheld, participants will be provided with a detailed rationale for the decision and will be informed of their right to escalate their complaint if they remain dissatisfied. For complex complaints that require an extended investigation period, participants will receive regular updates on the progress of their case. Keeping participants informed throughout the process ensures transparency and helps maintain their confidence in the organisation’s commitment to addressing concerns effectively. Once the complaint is resolved, follow-up measures may be undertaken to ensure that the participant is satisfied with the outcome and that any necessary systemic improvements have been implemented[cite: 1].

Escalation and External Avenues

Holistic Healthcare Management Services is committed to ensuring that participants have clear, accessible, and effective avenues for escalating complaints should they remain dissatisfied with the internal resolution process. Our complaints management process is designed to uphold the principles of fairness, transparency, and accountability while ensuring that participant safety, dignity, and wellbeing remain the highest priority[cite: 1].

Internal Escalation Process

If a participant is not satisfied with the outcome of the initial complaint resolution process, they may escalate their complaint to a higher level within the organisation. The escalation process includes the following steps[cite: 1]:

  • Supervisor or Team Leader Review: If the participant is dissatisfied with the handling of their complaint, they may request a review by a supervisor or team leader, who will reassess the matter and work towards a fair resolution[cite: 1].
  • Senior Management Review: If the issue remains unresolved, the complaint is escalated to senior management for further investigation. A designated senior manager will review the details of the complaint, liaise with all relevant parties, and ensure that the matter is handled with urgency and impartiality[cite: 1].
  • Board or Governance Committee Review (If Applicable): In cases where the complaint involves complex, systemic, or high-risk concerns, it may be escalated to the governing body or Board (if applicable) for review and final decision[cite: 1].

At each stage of the internal escalation process, participants will be provided with[cite: 1]:

  • A written response outlining the progress and decisions made[cite: 1].
  • Information on expected timelines for review and resolution[cite: 1].
  • Details of any additional steps they may take should they remain unsatisfied[cite: 1].
External Complaints Process

If participants feel that their complaint has not been resolved satisfactorily through the internal process, they will be provided with information and assistance to escalate their complaint to an external agency. The external agencies that participants may contact include[cite: 1]:

  • NDIS Quality and Safeguards Commission: The NDIS Quality and Safeguards Commission is the independent regulatory body responsible for handling complaints about NDIS service providers. Participants can escalate complaints regarding service quality, provider compliance, allegations of abuse, neglect, or exploitation, and breaches of the NDIS Code of Conduct[cite: 1].
    • Phone: 1800 035 544 (free call from landlines) or TTY 133 677[cite: 1]
    • National Relay Service: Call 1800 035 544[cite: 1]
    • Online Complaint Form: www.ndiscommission.gov.au[cite: 1]
    • Email: complaints@ndiscommission.gov.au[cite: 1]
  • Australian Human Rights Commission (AHRC): Complaints about discrimination, human rights violations, and equal access to services (Phone: 1300 656 419, Website: www.humanrights.gov.au)[cite: 1].
  • State or Territory Ombudsman: Complaints regarding government services or systemic issues within disability support services (Website: www.ombudsman.gov.au)[cite: 1].
  • Police and Child Protection Services: For complaints involving criminal conduct, abuse, or serious neglect (Emergency: 000, Non-emergency police: 131 444)[cite: 1].
Staff Responsibilities in Facilitating External Escalation

Holistic Healthcare Management Services recognises that some participants may require assistance in escalating their complaints externally. Staff members are responsible for[cite: 1]:

  • Providing clear and accessible information about external complaints options, including contact details and step-by-step guidance on how to make a complaint[cite: 1].
  • Assisting participants with documentation if they require help preparing written complaints or collecting supporting evidence[cite: 1].
  • Supporting participants through the process, including arranging interpreters, advocates, or disability support services to aid communication and ensure accessibility[cite: 1].
  • Ensuring that participants are not subject to retaliation or discrimination for making a complaint[cite: 1].
Reporting Serious Complaints to Authorities

Serious complaints that involve allegations of violence, abuse, neglect, exploitation, or immediate risk to a participant’s safety must be immediately escalated to the appropriate authorities[cite: 1]:

  • Senior Management: All serious complaints must be reported to senior management within Holistic Healthcare Management Services for urgent action[cite: 1].
  • NDIS Quality and Safeguards Commission: Reportable Incidents under the NDIS (Incident Management and Reportable Incidents) Rules 2018 must be lodged within specified timeframes[cite: 1].
  • Police and Emergency Services: If a participant is at immediate risk of harm, staff must call 000 and report the matter to police or emergency responders[cite: 1].
  • Child Protection Authorities: If a complaint involves a child at risk of significant harm, mandatory reporting obligations apply[cite: 1].

For each external escalation, the Holistic Healthcare Management Services Complaints Officer or delegate will ensure that the complaint is documented in full, the participant receives updates, and confidentiality and privacy are maintained in accordance with the Privacy Act 1988 (Cth) and the NDIS Code of Conduct[cite: 1].

Monitoring and Review

The complaints management system will be subject to continuous monitoring and periodic reviews to evaluate its effectiveness. Participant and worker feedback will be actively sought to identify areas for improvement and ensure the system remains relevant and accessible. Key performance indicators, such as resolution timelines, satisfaction rates, and recurrence of issues, will be tracked and analysed. Findings from these evaluations will inform updates to policies, procedures, and training programs, ensuring the organisation’s commitment to continuous improvement[cite: 1].

Roles and Responsibilities

Ref No Roles Responsibilities
1 Board and Senior Management
  • Provide strategic oversight of the complaints management system and ensure its alignment with organisational goals and legal requirements[cite: 1].
  • Allocate resources for staff training, system maintenance, and complaint resolution[cite: 1].
  • Review high-risk complaints and provide guidance on complex or unresolved issues[cite: 1].
2 Workers
  • Actively support participants in lodging complaints, ensuring accessibility and understanding[cite: 1].
  • Handle complaints with sensitivity and professionalism, promoting a culture that values feedback[cite: 1].
  • Implement resolutions and corrective actions as required, contributing to system improvements[cite: 1].
3 Complaints Coordinator
  • Maintain a detailed complaints register, documenting all complaints, investigations, and outcomes[cite: 1].
  • Monitor complaint trends and recommend systemic improvements to management[cite: 1].
  • Act as the primary liaison between participants, advocates, and the organisation throughout the complaints process[cite: 1].

Record Keeping

  • Complaints Register: Maintain a secure and centralised register for all complaints, ensuring documentation includes complaint details, investigation processes, resolutions, and outcomes[cite: 1].
  • Participant Feedback Records: Document all feedback, including positive comments and suggestions, to provide a comprehensive view of participant experiences[cite: 1].
  • Training Records: Record details of staff training sessions on complaints handling, including attendance, competency assessments, and updates to training content[cite: 1].
  • Audit Records: Retain documentation from internal audits of the complaints management system, highlighting findings and corrective actions implemented[cite: 1].

Related Documents

  • Complaint Report Form[cite: 1]
  • Feedback and Complaints Register[cite: 1]
  • Continuous Improvement Plan[cite: 1]
  • Continuous Improvement Register[cite: 1]
  • Participant Handbook[cite: 1]
  • Staff Handbook[cite: 1]
  • Staff Training Plan[cite: 1]
  • Training Attendance Record[cite: 1]
  • Service Agreement[cite: 1]

References

  • National Disability Insurance Scheme (Complaints Management and Resolution) Rules 2018[cite: 1].
  • Australian Privacy Principles[cite: 1].
  • National Disability Insurance Scheme Act 2013[cite: 1].

Policy Review

This policy will be reviewed annually to ensure alignment with best practices, legislative requirements, and feedback from participants, staff, and advocates. Updates will be made as needed to enhance its effectiveness and relevance[cite: 1].