Action 1.14

Implement a complaints management system

A well-designed complaints management system should incorporate the following elements:

• A clear policy framework defining the key elements of the system, and the roles, responsibilities and accountabilities of relevant individuals and committees
• Delegation of an individual or committee with responsibility for maintaining the integrity of the system, and receiving and coordinating the management of complaints
• A documented philosophy that acknowledges that complaints represent opportunities for improvement
• Compliance with state or territory requirements.

Support patients, carers and the workforce

Organisations may use different strategies to encourage the workforce, patients and carers to report complaints. These mechanisms should be documented in the organisation’s policies, procedures or protocols. The policy documents for complaints management should consider confidentiality of information, and responsibilities for:

• Receiving, investigating and managing complaints, and taking immediate action if required
• Grading the severity of complaints
• Communicating effectively with complainants about the management of the complaint
• Analysing complaints data, and identifying trends and opportunities for improvement.

Provide information about the complaints process to the workforce, patients and carers. The information should include a statement about the organisation’s philosophical approach to complaints management, and outline the formal and informal pathways to make a complaint. It may include information about how complaints are managed, the expected time frames for investigation and how the complainant will be notified of the outcome of the investigation.

Provide support for the workforce, patients and carers, and other individuals who are involved in incidents that lead to complaints. This may include:

• Nominating a support person to assist members of the workforce, patients or carers who wish to make a complaint
• Providing training to the workforce on complaints handling
• Ensuring that systems are in place to encourage the workforce, patients and carers to report complaints, and that support the analysis of the complaints process.

Involve the workforce, patients and carers in the review of complaints by:

• Inviting members of the workforce to join groups or committees responsible for reviewing complaints information or safety and quality performance data
• Providing information and training for consumers and the workforce to support them to understand data and measurements used by the organisation
• Providing safety and quality performance information to local community and consumer groups for feedback.

Refer to Action 2.11 for further information and strategies for involving consumers in committees.

Information on involving consumers in complaints handling committees is available from the Health Issues Centre.

Report on, and review, complaints

Roles and responsibilities of those overseeing the complaints management system (including data analysis) should be clearly defined. Responsibilities may include:

• Initiating an open disclosure process
• Following up complaints to ensure that improvements have been made, if appropriate
• Disseminating information about complaints and their quality improvement implications
• Reporting complaints to other parties (for example, complaints commissioners, regulatory authorities) under the relevant organisational obligations
• Linking complaints to the organisation’s policies on open disclosure, risk management, credentialing and scope of clinical practice, and quality improvement systems
• Linking complaints to the state or territory complaints management policy, if applicable
• Linking complaints to the procedure for communicating with the organisation’s insurer.

Use information from complaints to improve the safety and quality of care. Ensure that each complaint is reviewed by the member(s) of the workforce involved and the manager responsible for the operational area in which the complaint was generated. This enables lessons to be learned and local improvements to be implemented. Implement a system to verify that managers follow up complaints appropriately to ensure system integrity.

The complaints management system should enable prompt and effective review of information about complaints, in line with the organisation’s policies, procedures or protocols. Organisations may use a complaints register to ensure that complaints are managed efficiently and effectively, and that each complaint process is completed. This will help analyse and report complaints data appropriately, and will enable tracking of relevant complaints data into the risk management system. Regularly review the complaints register.

Implement classification and escalation processes to ensure that complaints associated with considerable risk are managed appropriately.

Define a reporting framework that clearly identifies the data that will be available and reported on at each level in the organisation. This will enable the workforce and members of the governing body to monitor and respond to system performance. A reporting schedule may help to identify when reports should be submitted to various committees or individuals, to ensure that issues are incorporated into relevant meeting agendas.

Provide comprehensive information to the governing body and management about complaints associated with major risks, and summary information, including trend reports, about all other complaints. Include information such as the actions taken as a result of a specific complaint or category of complaints, and indicators such as the time taken to complete actions stemming from complaints. This will enable the governing body and management to fulfil their clinical governance responsibilities.

Incorporate relevant information from the complaints management system into the risk management system and the quality improvement system, and report it to the governing body or management, if appropriate.

Periodically review the design and performance of the complaints management system. The governing body should consider whether it complies with best-practice design principles, and whether enough resources have been allocated to support effective clinical governance and risk management.

Examples of evidence

• Select only examples currently in use:
• Policy documents that describe the processes for recording, managing and reporting complaints
• Complaints register that includes responses and actions to deal with identified issues, and its schedule for review
• Training documents about the complaints management system
• Consumer and carer information and resources about the health service organisation’s complaints mechanisms
• Feedback from the workforce on the effectiveness of the complaints management system
• Feedback from consumers and carers on the analysis of complaints data
• Audit results of compliance with complaints management policies
• Evaluation reports that note the effectiveness of responses and improvements in service delivery
• Committee and meeting records in which trends in complaints and complaints management are discussed
• Reports or briefings on complaints provided to the governing body, the workforce or consumers
• Quality improvement plan that includes actions to deal with issues identified
• Examples of improvement activities that have been implemented and evaluated.

Implement a complaints management system

A well-designed complaints management system should incorporate the following elements:

• A clear policy framework defining the key elements of the system, and the roles, responsibilities and accountabilities of the workforce
• Delegation of an individual with responsibility for maintaining the integrity of the system, and receiving and coordinating the management of complaints
• A documented philosophy that acknowledges that complaints represent opportunities for improvement
• Compliance with state or territory requirements.

Support patients, carers and the workforce

Organisations may use different strategies to encourage the workforce, patients and carers to report complaints. These mechanisms should be documented in the organisation’s policies, procedures or protocols. The policy documents for complaints management should consider confidentiality of information, and responsibilities for:

• Receiving, investigating and managing complaints, and taking immediate action if required
• Grading the severity of complaints
• Communicating effectively with complainants about the management of the complaint
• Analysing complaints data, and identifying trends and opportunities for improvement.

Provide information about the complaints process to the workforce, patients and carers. The information should include a statement about the organisation’s philosophical approach to complaints management, and outline the formal and informal pathways to make a complaint. It may include details about how complaints are managed, the expected time frames for investigation and how the complainant will be notified of the outcome of the investigation.

Provide support for the workforce, patients and carers, and other individuals who are involved in incidents that lead to complaints. This may include:

• Nominating a support person to assist members of the workforce, patients or carers who wish to make a complaint
• Providing training to the workforce on complaints handling
• Ensuring that systems are in place to encourage the workforce, patients and carers to report complaints, and that support the analysis of the complaints process.

Involve the workforce, patients and carers in the review of complaints by:

• Inviting members of the workforce to join groups or committees responsible for reviewing complaints information or safety and quality performance data
• Providing information and training for consumers and the workforce to support them to understand data and measurements used by the organisation.

Refer to Action 2.11 for further information and strategies for involving consumers in committees.

Information on involving consumers in complaints handling committees is available from the Health Issues Centre.

Report on, and review, complaints

Roles and responsibilities of those overseeing the complaints management system (including data analysis) should be clearly defined. Responsibilities may include:

• Initiating an open disclosure process
• Following up complaints to ensure that improvements have been made, if appropriate
• Disseminating information about complaints and their quality improvement implications
• Reporting complaints to other parties (for example, complaints commissioners, regulatory authorities) under the relevant organisational obligations
• Linking complaints to the organisation’s policies on open disclosure, risk management, credentialing and scope of clinical practice, and quality improvement systems
• Linking complaints to the procedure for communicating with the organisation’s insurer.

Use information from complaints to improve the safety and quality of care. Ensure that each complaint is reviewed by the member(s) of the workforce involved and the manager responsible for the operational area in which the complaint was generated. This enables lessons to be learned and local improvements to be implemented. Implement a system to verify that managers follow up complaints appropriately to ensure system integrity.

Define a reporting framework that clearly identifies the data that will be available and reported on at each level in the organisation. This will enable the workforce and members of the governing body to monitor and respond to system performance.

Provide comprehensive information to the governing body and management about complaints associated with major risks, and summary information, including trend reports, about all other complaints.

Incorporate relevant information from the complaints management system into the risk management system and the quality improvement system, and report it to the governing body or management, if appropriate.

Periodically review the design and performance of the complaints management system. The governing body should consider whether it complies with best-practice design principles, and whether enough resources have been allocated to support effective clinical governance and risk management.

Examples of evidence

Select only examples currently in use:

• Policy documents that describe the processes for recording, managing and reporting complaints
• Complaints register that includes responses and actions to deal with identified issues, and its schedule for review
• Training documents about the complaints management system
• Consumer and carer information and resources about the health service organisation’s complaints mechanisms
• Feedback from the workforce on the effectiveness of the complaints management system
• Feedback from consumers and carers on the analysis of complaints data
• Audit results of compliance with complaints management policies
• Evaluation reports that note the effectiveness of responses and improvements in service delivery
• Committee and meeting records in which trends in complaints and complaints management are discussed
• Reports or briefings on complaints provided to the governing body, workforce or consumers
• Quality improvement plan that includes actions to deal with issues identified
• Examples of improvement activities that have been implemented and evaluated.

MPSs or small hospitals that are part of a local health network or private hospital group should adapt and implement the established complaints management system.

Small hospitals that are not part of a local health network or private hospital group should develop or adapt an organisation-wide complaints management system that includes:

• A policy for receiving and reporting on complaints and incorporating issues into the organisation’s quality improvement system
• Clearly defined roles, responsibilities and accountabilities for individuals and groups involved in the complaints management system
• Regular reports on the analysis of complaints data and the actions to manage issues identified
• Processes for supporting patients, carers and families to make complaints and to review organisational safety and quality performance information
• Workforce training in complaints handling, and involvement of the workforce in analysing complaints and feedback from complaints
• Periodic review of the effectiveness of the organisation’s complaints management system.

Examples of evidence

• Select only examples currently in use:
• Policy documents that describe the processes for recording, managing and reporting complaints
• Complaints register that includes responses and actions to deal with identified issues, and its schedule for review
• Training documents about the complaints management system
• Consumer and carer information and resources about the health service organisation’s complaints mechanisms
• Feedback from the workforce on the effectiveness of the complaints management system
• Feedback from consumers and carers on the analysis of complaints data
• Audit results of compliance with complaints management policies
• Evaluation reports that note the effectiveness of responses and improvements in service delivery
• Committee and meeting records in which trends in complaints and complaints management are discussed
• Reports or briefings on complaints provided to the governing body, the workforce or consumers
• Quality improvement plan that includes actions to deal with issues identified
• Examples of improvement activities that have been implemented and evaluated.