Feedback Policy

Purpose

This policy provides Hunter Primary Care (HPC) an effective and fair organisation-wide framework for the receipt, capture and response to feedback, including complaints, received by HPC regarding our organisation, our services and the conduct of our personnel.  

The purpose of this policy is to: 

  • Clearly communicate how HPC manages and responds to feedback from external stakeholders, including consumers, in accordance with good practice and relevant standards 
  • Describe the complaints management practices of HPC and enhance the transparency of its operations  
  • Give individuals who make or have an interest in a complaint a clear understanding and reasonable expectation of the way complaints received by HPC will be managed 
  • Provide clear guidance to HPC staff in relation to feedback received from external parties, regarding services provided by HPC 

Scope

This policy is relevant to all HPC staff in all areas. 

It is to be used when dealing with any feedback received by HPC, relating to services provided to customers and the community (including clients, patients, friends and family, GPs, members and partners of HPC or any of its services and programs). 

The policy applies to feedback provided and complaints made formally via a letter, email or web form, as well as feedback given verbally in person or over the phone to any member of staff. It covers solicited and unsolicited feedback. Feedback can be provided anonymously. 

The policy should be read in conjunction with the Whistleblower Policy (BOARD 53) if there is any suggestion of reportable conduct by or on the part of HPC. 

The policy does not apply to complaints or grievances by HPC personnel. These are treated separately under the Conflict Resolution Procedure (HR 13). 

Policy Statement

At HPC, we welcome feedback about our services and actions. We believe that we can learn from our experiences, both positive and negative, and we see that having clear channels for feedback and a robust complaints process as central to doing that. 

We set high standards for ourselves and work to deliver services and supports that meet the needs of our members, patients and clients; and we welcome feedback that lets us know how we are doing. This includes positive feedback and compliments about things that have gone well; but we also understand that sometimes things can go wrong or that people are disappointed. It is important to us to also identify those instances and to have the opportunity to investigate and address both the cause and issues arising. 

We seek to capture as much feedback as possible, particularly feedback from or on behalf of patients and clients, funders and the wider community, and we believe that effective and timely response to feedback is an important tool for maximising the community’s satisfaction with HPC overall and its various services. 

To this end, we commit to ensuring that mechanisms for providing feedback are readily available to consumers, family members, friends or carers, and external stakeholders. Feedback may be written or verbal, and can be made at any time face-to-face, via telephone call, online from the Hunter Primary Care website or in writing (by email, fax, hand-delivered, or via post).  

We ensure HPC staff at all levels are willing and able to receive feedback at any time, and know what action they should take. 

We will ensure that our process: 

  • Is clearly described in a policy made available on the HPC website, and in hard copy on request, and  
  • Provides for the receipt and management of anonymous feedback, including complaints. 

We will also ensure that no negative consequences or retribution occurs for any consumer or external stakeholder that makes a complaint to or about us. 

To assist people wishing to provide feedback or follow up a matter raised, we will: 

  • Ensure that our Feedback Policy is always available on the HPC website,  
  • On request, provide a printed copy of our Feedback Policy to any interested stakeholder, and 
  • If required, explain our Feedback Policy in an appropriate fashion (including via translating or interpreting services, or using communication aids as appropriate). 

1. How feedback can be provided

Hunter Primary Care
PO Box 572
Newcastle NSW 2300

  • Fax written feedback to (02) 4925 2268
  • Requesting a face-to-face meeting the staff member or Manager of the relevant Hunter Primary Care service at one of our offices

The following services can assist with making a call to us: 

  • Translating and Interpreter Service (TIS) for non-English speakers 131 450
  • TTY service 133 677 
  • National Relay Service Speak and Listen (if you are deaf, have a hearing impairment or speech impairment) 1300 555 727  

You can also provide feedback at any time as part of any conversation or appointment with any member of Hunter Primary Care staff. 

If you are making a complaint, please provide as best you can, specific details of the incident, events or behaviour that you are concerned about. This will assist us to understand and address your complaint as efficiently as possible. 

2. How feedback is approached

We value all feedback from our stakeholders. 

When feedback is positive, we pass on compliments to the staff member/s involved, and ensure their line manager/s are aware of it. 

Similarly, we take all complaints seriously, and will investigate each identified issue or incident in accordance with this policy. We take great care in assessing each complaint to ensure that every effort is made to understand the information the complainant is conveying. 

Wherever possible, we seek to address feedback and resolve issues arising at the first point of contact.  

We will approach all complaints and complainants with respect and sensitivity. We will ensure all complainants are able to access any supports required to assist them with making and resolving a complaint, including advocates, interpreters and communication aids.  

We will also treat all staff, volunteers and contractors fairly throughout any complaint process in which they are involved. 

We will investigate all complaints in an objective and equitable manner, and in accordance with this policy. We undertake to collect sufficient information to allow for assessment and assigning priority to the complaint by a person or team that specialises in the complaint topic.  

We commit to upholding confidentiality wherever possible throughout the complaint management process; but we accept that there may limitations on confidentiality when investigating specific events and/or when appropriately managing the matters that a complaint may raise. 

We aim to resolve all complaints within 35 calendar days of notification. We will liaise with the complainant, and with any identified parties or respondents, about the progress of the complaint process and about the outcome. 

We will provide a mechanism for review if the complainant is not satisfied with the outcome of the initial investigation. 

We will report monthly to the Executive on the status of received complaints to identify trends, eliminate causes of complaints, and to improve the organisation’s operations.  

3. How positive feedback will be handled

When we receive positive feedback, our priority is to ensure that it is passed on to the correct people. This is usually any staff members involved, and their managers.  

To do this, we record the details of feedback provided, and advise the relevant manager so that outstanding conduct or actions can be acknowledged.  

4. How complaints will be handled

Our priorities for handling complaints are:

  • To understand what happened,
  • To identify any contributing failures by HPC or opportunities for improvement,
  • To take any actions necessary to rectify and avoid a repeat, and
  • To provide an appropriate response to the complainant.

Our process for managing complaints involves the following steps:

  1. Receiving the complaint
  2. Registering the complaint
  3. ‘First response’ triage and acknowledgement
  4. Initial assessment of the complaint
  5. Investigating the complaint (if necessary)
  6. Responding to the complaint
  7. Resolving the complaint

The below chart illustrates the steps, and shows what we do at each stage, indicates where the complainant is likely to be engaged.

We use a secure electronic system to hold the details of complaints and assist with our complaint management, monitoring and reporting processes. 

If you make a complaint, you can expect us to follow this process, and to involve you at each appropriate point. 

Complaints Handling Process_Diagram

When a complaint is received we nominate an appropriate person to manage the complaint process (based on the details known at time of reporting), and we will contact you within five days to formally acknowledge receipt of your complaint.  

We believe that all complaints require a fact-finding process to determine what has happened and what course of action is required in response. This may be an assessment or a full investigation – our action and process need to be appropriate to the seriousness of the complaint and issues raised. 

We treat all parties fairly and with respect throughout any investigation process, and do not attribute blame. We offer and organise support as needed to ensure all parties feel as comfortable as possible throughout the process.  

Where we identify that something has gone wrong, we commit to ‘open disclosure’ and to sharing this with the impacted people. 

At the conclusion of a complaint investigation, we use the findings to develop recommendations for action, and will provide a formal response that outlines the investigation, findings and actions taken. We commit to remedial or improvement actions that: 

  • Are fair to all parties, proportionate to the issues identified, and based on the evidence available,  
  • Address any systemic, process or service issues identified, and 
  • Are informed by the principles of public interest and good governance. 

We also send a copy of the final response to any external parties involved (e.g. Health Care Complaints Commission). 

We consider a complaint closed when this final response has been sent. 

5. How outcomes are reviewed

If, as a complainant, you are not satisfied with outcome of an HPC complaint investigation and the final response you receive, you have a right to seek a review of the initial outcome. You do this by lodging an application for review with the CEO of HPC within 30 days. 

The CEO will then form a Complaints Committee of suitably-qualified people (relevant to the service or subject of the complaint) to consider the matter. If the complaint is about the decision or action of a specific staff member, we will ensure that person is excluded from the Complaints Committee. 

You have the right to make a written submission to the Complaints Committee. This needs to be provided to the CEO within 14 days of the application for review being lodged.  

The Complaints Committee will consider the matter and any submission you make. It may, at its discretion, interview persons that it considers will assist in its deliberations; and will reach a decision and provide a written report of the decision and rationale. 

If you are dissatisfied with the outcome of a review, you have the right to take the matter further to the relevant external complaints organisation (e.g. NSW Ombudsman). 

6. How complaints are reported upon

We believe that feedback (including complaints), and how we manage it, are key indicators of our performance. We set Key Performance Indicators (see below in this document), and we regularly review the numbers and details of complaints to monitor and improve our performance, and to allow us to identify any trends. Only de-identified information is included in these summary reports. 

From time to time, it is necessary for us to report or communicate within HPC on individual complaints or on the specific matters raised in feedback. We ensure that confidentiality is maintained at all times, and feedback is always de-identified when it is discussed in team meetings, transmitted in emails, or reported to any meeting or Board Committee. 

Occasionally, we develop case-studies of matters raised by complaint to help other staff learn from the experience. Where personal details may be relevant to the case study, we seek the consent of the persons involved prior to any case study being prepared. 

7. How special circumstances are managed

7.1 Client authorities 

If feedback is provided on behalf of a client, and we need further information, we will seek authority from the client before we investigate. We cannot access information about a person’s health or services from any third party without their permission (or that of their nominated person responsible). 

7.2 Anonymous feedback

We undertake to treat matters raised anonymously with the same rigour and seriousness as feedback from identified individuals. And when a complaint is made anonymously, we will investigate and resolve as best we can with the details provided.  

For the purposes of this policy, anonymous feedback includes that provided by individuals who are unnamed as well as feedback given under a false name (pseudonym). 

We understand that sometimes a complaint may be made by or on behalf of a person who wishes to remain anonymous for one of a variety of reasons; and a complaint investigation may still be possible and may be warranted, particularly if the complainant raises health and safety concerns, or concerns about potential professional misconduct. 

Complaint investigation and resolution can be made more problematic if identities of key parties are not provided, as this may limit HPC’s ability to obtain information.  

When a person makes an anonymous complaint via the telephone, we will request them to identify themselves to assist with effective complaint resolution. When a calling complainant wishes to remain anonymous, however, we will respect this.  

When a complaint is made anonymously in writing (including online) and it is not possible to have a conversation about the limitations of anonymity, we will proceed with the details provided. 

When a complaint is made anonymously, the final response will be placed on the file to close the complaint. 

We acknowledge that at times an anonymous complaint may inadvertently reveal the identity of the complainant or that their identity may be apparent from the complaint details. We will still treat the complaint itself as anonymous, and not share or use the personal details of the party that wished to remain anonymous, unless there is a legal obligation 

7.3 Old complaints

We treat old matters or delayed complaints with the same rigour and seriousness as current ones.  

While normally a complaint is made a short period of time after the event or series of events that caused the problem, we understand that on occasion and for various reasons, a complaint may not be raised with HPC until some time after the fact.  

If the passage of time between the event and the complaint is considerable, it may affect HPC’s ability to investigate a complaint because people in key roles may have changed or they may no longer recall relevant details. We still take each complaint seriously and do our best to understand what occurred and to resolve it. 

Although it may not be possible to fully understand all the facts of the matter, we will make attempt to achieve satisfactory resolution.  

When we identify that a complaint is an old complaint (which may be when we receive it, or may become apparent through investigation), we will ensure that that the limitations on our investigation are explained to the complainant at that time to help manage their expectations. 

7.4 Declining to deal with a complaint

While HPC takes all complaints seriously, we reserve the right to decline to investigate a complaint under certain circumstances. 

We may decline to deal with a complaint because we believe it is: 

  • Vexatious or frivolous, 
  • Outside HPC’s jurisdiction,  
  • Under investigation by some other competent person or body, or  
  • The subject of legal proceedings (or has been the subject of legal proceedings). 

Before we make a decision to decline to deal with a complaint, we will conduct a preliminary investigation of details available to ensure that our decision is sound, and founded in fact.  

If we decline to detail with a complaint, we will advise the complainant of the reasons for the decision as well as, where appropriate, other agencies that may be able to assist them with their concerns. 

7.5 Matters requiring mandatory notification 

In some cases a complaint made to HPC raises issues that requires mandatory notification or referral by HPC to another party, because of our duty of care, or due to legal or contractual obligations.  

External bodies that may need to be involved in a complaint, depending on the detail, include for example: 

  • NDIS Quality and Safeguards Commission – where the safety of an NDIS participant is impacted 
  • NSW Family and Community Services – regarding child protection concerns 
  • NSW Ombudsman’s Office – regarding abuse of adults with disability in the community 
  • Australian Health Practitioner Regulation Agency or a professional registration body – where professional misconduct is indicated 
  • NSW Police – where criminal conduct is involved 
  • Office of the Australian Information Commissioner – regarding breaches of privacy 

Further guidance in relation to mandatory reporting is available in the relevant HPC policy documents. 

7.6 Feedback about sub-contractors

If feedback is received, about a service that HPC has engaged a sub-contractor to perform, we will in the first instance pass the feedback on to the relevant sub-contractor. In the case of a complaint, we will refer it for their investigation and resolution.  

Where this occurs, we will liaise with the sub-contractor about the progress of the complaint investigation, and the resolved outcome. 

We retain ultimate responsibility for ensuring that all feedback regarding HPC services is handled appropriately, including that complaints made about HPC services are investigated and managed appropriately, and that we feel the resolution is satisfactory. 

7.7 Complaint management exceeding 35 days

Wherever possible, we seek to satisfactorily resolve each complaint within 35 days of receipt. 

If at 35 days from the date of receipt of a complaint, the investigation has not been concluded, or the matter not yet resolved, we will contact the complainant to provide an update about progress, and a revised date by which a full response should be expected. 

8. How matters can be escalated

If you have a complaint that you feel has not been satisfactorily resolved, you can escalate this to one of the authorities listed below:

Performance Indicators

To measure and report on our performance in relation to feedback, we focus on our management of complaints. We set ourselves following key performance indicators (KPIs): 

  1. Percentage of feedback received formally where the feedback source has received acknowledgement of the feedback within 5 business days (Benchmark 100%) 
  2. Percentage of complaints resolved within 35 calendar days from date complaint received, i.e. finalised to the point where there is no further action to be taken by Hunter Primary Care Limited in relation to the feedback source (Benchmark 90%). 

Within HPC, we report regularly on feedback received and on our performance against these KPIs.

Roles and Responsibilities

Role Responsibility
Board and Executive Monitor complaint activity and trends organisation-wide
Senior Management Oversee the appropriate management of complaints within their area

Ensure mandatory reporting and escalation of individual complaints as necessary

Prepare regular reports on complaints management
Line Managers Support and guide staff in receiving and managing complaints
All staff Receive and record complaints from external stakeholders

Know how to respond to, action and escalate complaints

Supporting Procedures

  • Complaints Management Procedure (GEN 49.1)

References / Related Documents

  • ACHS Evaluation and Quality Improvement Program (EQuIP) 
  • headspace Model Integrity Framework 
  • NDIS Practice Standards and Quality Indicators (version 4) 
  • RACGP Standards for After Hours and Medical Deputising Services (5th Edition) 
  • Incidents Policy (GEN 07) 
  • Open Disclosure Policy (GEN 34) and Open Disclosure Guidelines (GEN 36) 
  • Mandatory Notification of Health Practitioners (HR 69) 
  • Child Protection and Risk of Harm Notification (GEN 46) 
  • Responding to Allegations of Risk of Harm to Individuals (GEN 53) 
  • Whistleblower Policy (BOARD 53) 

A copy of the supporting procedure and related documents can be requested by emailing communication@hunterprimarycare.com.au

Definitions

A complaint is any constructive or negative piece of feedback received about HPC or any of its service or people. Complaints may be formal or informal.

Complainant is the person who lodges the complaint with HPC. The complainant may be a client, or a client’s carer or family member, or staff of a partner organisation or member of the public.

A grievance is a formal, itemised complaint to management that one or more employees have been unfairly treated or there has been violation of the contract of employment or collective bargaining agreement.

Feedback is any input, comment or reflection received from a stakeholder about HPC of any of its services or people. This includes positive feedback (compliments) as well as complaints, from internal or external sources. Feedback may also be about other providers / organisations that are associated with the delivery of services by HPC.  Feedback does not include general enquiries that occur in the normal course of business or grievances.

Line Manager refers to a direct manager, supervisor or team leader of the staff member or service involved in the complaint.