Policy for Client Complaints & Feedback

Client Complaints and Feedback Policy

1. Policy Statement

1. Coastal Motion Therapy Services believe that all complaints, feedback, and grievances provided by our Clients are an important opportunity to improve the quality of our services. Through this Policy we ensure that our Clients, their families, carers, and advocates are aware of their right to complain and the procedure to follow to lodge their complaint, feedback or grievance. All complaints, feedback, and grievances shall be treated confidentially, where possible, and Coastal Motion Therapy Services shall take all reasonable measures to ensure complainants are protected from reprisals and/or victimisation.

2. Coastal Motion Therapy Services are committed to working collaboratively together with Clients to continue to deliver a high standard of services that meet the needs of Clients and their families.

3. When managing complaints Coastal Motion Therapy Services shall take a focus on identification of risk and the prevention of errors in order to reduce the potential dissatisfaction and harm to Clients.

4. Coastal Motion Therapy Services shall give all Clients access to lodging complaints, feedback, and grievances without fear of retribution or victimisation and shall ensure that all received complaints, feedback, and grievances are considered, appropriately referred and actioned upon.

2. Definitions

1. Informed consent means permission an individual gives to sharing information, either implied or explicit, after they have demonstrated that they understand the purpose of the request and the likely outcomes of that consent. 

2. Any reference to a Person-centred Approach also includes family-centred approach when considered in relation to providing services to children.

3. Any reference to Feedback also means a reference to a complaint, a grievance or a dispute.

3. Communication

1. This Policy is available in pictorial and easy read format.

4. Quality Assurance

1. Coastal Motion Therapy Services shall deliver services in accordance with its lawful obligations, rules and regulations that set standards such as:

 Support for Clients to meet their aspirations and to participate in the community;

 Respect for Clients’ right to choose;

 Non-Discrimination;

 Culture of Respect.

2. This Policy shall be read in consultation with Code of Conduct and Ethical Guidelines for each discipline in which staff is employed at Coastal Motion Therapy Services. Health Practitioners have a responsibility to be familiar with their discipline specific Code of Conduct and Ethical Guidelines and to comply with the Health Practitioner Regulation National Law, where appropriate. The Code of Conduct and Ethical Guidelines outline professional standards and guidelines to support practitioners in providing high quality healthcare to Clients.

3. All unregistered health practitioners employed or otherwise working for Coastal Motion Therapy Services are required to comply with the South Australian Code of Conduct for Unregistered Health Practitioners which promotes safety and quality in health services for those not covered by the Australian Health Practitioner Regulatory Agency.

4. Where a health practitioner has a serious concern about the treatment provided by another health practitioner the matter shall be referred to the Health and Community Services Complaint Commissioner in accordance with the Code of Conduct in addition to the internal reporting requirements of Coastal Motion Therapy Services as outlined in the Duty of Care and Incident Management Policy.

5. Procedure

1. Any Client of Coastal Motion Therapy Services as well as their family member, carer, advocate, guardian or other nominee has a right to lodge their feedback, complaint, grievance or dispute about the services or the way they are delivered at any time during or after receiving said services using any available means for lodging this Feedback.

2. Complaints can be made by:

 Face-to-face verbal communication to the person delivering services or to the Director;

 Telephone call; 0402 985 157

 Email; admin@coastalmotiontherapy.com.au

 Written communications to Australian Health Practitioners and Regulation Board for Registered Health Professionals and the Health and Community Services Complaints Commissioner for Unregistered Health Professionals.

3. Children, young people and their families/carers are also able to make complaints via the methods above and support can be provided to them to make a complaint in the method most appropriate to them and their language and development requirements.

4. Complaints about abuse or neglect can also be made to the National Abuse and Neglect Hotline on 1800 880 052.

5. If complaints are not resolved within Coastal Motion Therapy Services they can also be made to the 

NDIS Commission (including anonymously) by:

 Phoning: 1800 035 544 (free call from landlines) or TTY 133 677. Interpreters can be arranged.

 National Relay Service and ask for 1800 035 544.

 Completing a complaint contact form.

6. For the purpose of achieving the best outcome possible Clients are encouraged to include the following information in their Feedback: 

 Detailed description of the matter of the Feedback: persons involved, location, date, time, sequence of events and their results;

 Actions that the Client would like Coastal Motion Therapy Services to take to resolve the complaint;

 Preferred means of communication between the Client and Coastal Motion Therapy Services in regard to the Feedback, investigations and actions taken.

7. Coastal Motion Therapy Services shall respond promptly and fairly to any Complaint/Feedback requiring follow-up action or investigation, aiming to provide an outcome within 1 month and ensuring that the principles of procedural fairness are upheld during the management and resolution of any complaint made.

8. Coastal Motion Therapy Services shall take reasonable action to attempt to resolve any complaints, grievances or disputes by consulting with Clients and staff as relevant.

9. Where such action is not sufficient the matter shall be referred to the relevant legislative authority: Australian Health Practitioner Regulation Agency (AHPRA) (Registered Practitioners) or Health and Community Services and Complaints Commissioner (Unregistered Practitioners).

10. Management of complaints shall be conducted in a confidential and courteous manner according to the Collecting and Handling Information Policy without any form of retribution against the Client.

11. Staff issues or positive feedback shall be addressed with the staff members in question promptly to encourage everyday practice reflection and self-development.

12. Where resolution provides for an increase in service offerings, those shall be considered against budget and staff expertise. Partnerships with other organisations may provide for an increased service offering where budget and expertise do not allow Coastal Motion Therapy Services to further expand on the services offered.

6. Responsibilities

1. Staff/Contractors

• Receiving Complaints: Listen actively and respectfully to complaints, ensuring participants feel heard and supported.

• Documentation: Accurately record complaints, including all relevant details, and ensure they are submitted to the appropriate personnel or system for follow-up.

• Immediate Action: Address minor concerns promptly within their capacity or escalate serious complaints to management as required.

• Compliance: Follow organizational policies and NDIS Code of Conduct in handling complaints, ensuring confidentiality and safeguarding participant rights.

• Facilitating Resolution: Support the resolution process by providing relevant information, assisting in mediation, and ensuring outcomes are communicated effectively.

2. Directors

• Oversight: Ensure the complaint handling processes align with NDIS standards and promote a culture of continuous improvement.

• Management: Address and oversee the resolution of complex or escalated complaints to ensure satisfactory outcomes.

• Leadership: Provide guidance and training to staff on complaint management procedures and participant rights.

• Accountability: Monitor compliance with NDIS requirements, including accurate documentation, reporting, and safeguarding practices.

• Stakeholder Engagement: Communicate effectively with clients, staff, and external parties to resolve complaints and maintain trust.

7. Advocacy

1. Clients have the right to have an advocate or representative to assist them in making a complaint or providing feedback.

2. Where a client expresses a wish for an advocate or representative to assist them, Coastal Motion Therapy Services shall assist the client in accessing and contacting an advocate. Further information is available here: https://www.ndiscommission.gov.au/participants/disability-advocacy. Clients may also use the Disability Advocacy Finder available here: https://disabilityadvocacyfinder.dss.gov.au/disability/ndap/

3. There may be occasions where Clients are not comfortable requesting assistance from Coastal Motion Therapy Services to provide information on advocates or representatives. Further information on making complaints, rights and processes can be found on the NDIS website: https://www.ndiscommission.gov.au/about/complaints

4. Advocates and representatives can and should be involved in the management of a complaint at the request of the client.

8. Investigations

1. Not all feedback, complaints, disputes or grievances will require an investigation.

2. Where an investigation is necessary, it shall be undertaken in accordance with the provisions of the Principles of Natural Justice and Procedural Fairness and shall follow the process:

 Collect evidence (this may involve direct observation, collation of documentation relating to the complaint, interviews with parties to the complaint, etc.);

 Assemble and consider the evidence;

 Compare the findings with relevant standards, protocols or guidelines, whether national or local, to establish the facts, draw conclusions about causation and make recommendations for actions to minimise risk;

 Develop an improvement strategy with prioritised actions, responsibilities, timescales and strategies for measuring the effectiveness of actions;

 Implement the improvement strategy and track progress, including the effectiveness of actions.

3. The investigation process shall be tailored to the Client’s needs and/or disability.

4. Where possible and appropriate the Client shall be kept informed of the progress of the investigation and its outcome and offered support during this process.

5. Incidents that require reporting shall be reported promptly to the relevant authorities such as Department of Human Services, SA Police, etc. as outlined in the Duty of Care and Incident Management Policy

9. Documentation

1. Details of the Feedback, investigations, reports and outcomes shall be recorded and managed in a confidential manner and stored securely in accordance with Collecting and Handling Information Policy.

2. Records shall contain:

 Details of the initial Feedback received from the Client;

 Communications with the Client regarding the matter;

 Staff members responsible for addressing the matter;

 Investigations;

 Actions taken;

 Outcome and whether and how the outcome was reported to the relevant authorities and parties.

3. Documentation shall be kept for 7 years.

10. References

1. Client Feedback Form

2. Collecting and Handling Information Policy

3. Duty of Care and Incident Management Policy

11. References

 National Disability Insurance Scheme (Complaints Management and Resolution) Rules 2018