Improving complaints management

By working with agencies to improve complaint management, the Queensland Ombudsman is helping to deliver fair and accountable public administration in Queensland.

An important part of the Office’s purpose is to provide advice, training, information and other help to agencies to improve the quality of administrative practices and procedures.

The Ombudsman conducts a Complaint Management System (CMS) reviews program to evaluate the operation of agency CMSs. This process helps agencies to improve their complaints management practice.

CMS reviews consider six key elements:

• policy and procedures
• external visibility and accessibility
• internal communication and training
• complaints process operation
• maintenance and improvement
• external reporting.

In 2018 year, officers from the Queensland Ombudsman completed CMS reviews of four departments, five local councils and seven public authorities (universities and hospital and health services). Of these, eleven were initial reviews and five were follow-up reviews.

After an initial review is completed, officers monitor the agency’s progress by regularly following up for updates. Once the agency advises the officers that the recommendations have been implemented, the agency is scheduled for a follow up review. Depending on the recommendations, the follow up review is done by checking website information or an onsite visit.

It is encouraging that only two of the five follow up reviews still required further recommendations. In response to the increasing accountability expectation and drive for continuous improvement, state government departments and agencies and local governments must have robust systems in place to efficiently and effectively manage complaints.

The Public Service Act 2008 requires departments and other state agencies to implement a CMS for customer complaints that complies with the current Australian Standard. The Local Government Act 2009 and related regulations outlines the requirements for local councils.

Policy and procedures (33 recommendations in the 2018 review)

Policy and procedures should outline an agency’s direction and commitment to the principles underpinning the CMS. Procedures should identify the stages and steps involved in managing complaints.

• The Australian Standard provides that an agency should have an explicit complaint management policy and the policy should be supported by procedures detailing how complaints will be managed.
• The Local Government Regulation 2012 (s306) requires council CMSs to have supporting policy and procedures.

For information on what to include in an agency’s policy and procedures, view the policy and procedures guide.

External visibility and accessibility (22 recommendations in the 2018 review)

The public must be able to easily find information about how to make a complaint, and the website needs to include general complaints information, and the CMS policy and procedures.
 
Common recommendations for improvement related to:

• limited complaints information being available
• complaints information being inconsistent with the agency’s CMS policy/procedures
• CMS policy/procedures being inaccessible
• CMS policy/procedures not addressing available complaint channels (or providing restricted channel e.g. in writing only)
• lack of reasonable assistance options available to customers to make a complaint 

For information on what to include on an agency’s website, view the website complaints visibility and accessibility guide.

Internal communication and training (17 recommendations in the 2018 review)

Internal communication of the CMS, and training on effective complaints management principles including CMS policy and procedures, are critical to staff awareness and understanding of the CMS. Complaints handling staff should be trained in receiving and resolving complaints from disadvantaged and vulnerable people who need assistance, early resolution and managing unreasonable complainant conduct.

Common recommendations for improvement related to:

• no or limited regular and effective communication to all staff about the CMS and its operation
• no or limited training being provided to relevant complaints handling staff
• CMS policy/procedures not addressing CMS communication or training to staff.

The Ombudsman provides training programs on effective complaints management and managing unreasonable complainant conduct training for agency staff.

Complaints process operation (32 recommendations in the 2018 review)

Effective complaints resolution is about achieving right outcomes in a fair and timely way and providing meaningful responses. Central to effective complaints resolution is the receiving, recording, assessing, reviewing and responding stages of the complaints process.

Common recommendations for improvement related to:

• complaints not being acknowledged
• CMS timeframes for acknowledgement or resolution being exceeded or unmonitored
• information about available internal or external review options not being provided to complainants
• complaint outcome advices, and complaints not being registered or not being recorded with sufficient relevant supporting information
• CMS policy/procedures didn’t sufficiently or correctly address managing unreasonable complainant conduct, the complaints model, the CMS scope/complaint definition and identification, complaints recording, complaint remedies and internal and external review options.

For further details, view the effective complaints management information on our website.

Maintenance and improvement (13 recommendations in the 2018 review)

Continual improvement of the CMS is one of the guiding principles for effective complaints management in the Australian Standard.

• The standard provides that maintenance and improvement of a CMS includes:
• collection of information - record the performance of the complaints process
• analysis and evaluation of complaints - identify systemic and recurring/single incident problems and trends and to eliminate underlying causes of complaints
• satisfaction with the CMS - regular action to determine levels of satisfaction, including surveys of complainants
• monitoring of the CMS - performance of the process should be measured against predetermined criteria
• auditing of the CMS - regular reviewing of the process in order to evaluate performance on compliance with procedures and suitability to achieve objectives
• management review of the CMS.

The Local Government Regulation 2012 requires that internal reports are occasionally provided to senior management about the operation of the CMS. Reporting on CMS operation should include analysis of individual or aggregate complaints data to identify complaint trends, systemic or recurring issues to inform continuous improvement of systems, policies, procedures, practices and service delivery, and monitoring/reviewing the effectiveness of the CMS. The Regulation also requires that mechanisms are in place to identify, analyse and respond to complaint trends and monitor the effectiveness of the CMS (e.g. by monitoring the time taken to resolve complaints).

Common recommendations for improvement related to:

• CMS maintenance and improvement functions not being conducted
• CMS policy/procedures not fully addressing maintenance and improvement functions and allocated responsibilities.  

External reporting (11 recommendations in the 2018 review)

It is important for accountability and transparency purposes that public agencies externally report on the operation and performance of their CMS.

This may include information on the agency's commitment to effective complaints management and its compliance with mandatory requirements or recognised standards, an assessment of the agency's performance in complaints management, including complaint statistics, the results of any review of the complaints system, effectiveness and/or any significant systemic improvements identified and implemented during the reporting period.

Common recommendations for improvement related to:

• complaints reporting not including all required information (e.g. numbers of complaints resulting in further and no further action)
• reported numbers of received and finalised complaints appearing unreliable or inconsistent with CMS scope and agency operations. 
• CMS policy/procedures didn’t address reporting requirements.