NDIS Complaints and Feedback Framework

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Disclosure Log - FOI 24/25-1037 DOCUMENT 1

NDIS Complaints and

Feedback Framework

     February 2024

            Page 1 of 98

Disclosure Log - FOI 24/25-1037

Contents

  1.      Context ......................................................................................................................3

      1.1   Background ........................................................................................................... 3

      1.2   Purpose ................................................................................................................. 3

      1.3   Scope .................................................................................................................... 3

  2.      Our approach to manage feedback and complaints ..................................................4

      2.1    Principles .............................................................................................................. 4

      2.2   Timeframes ........................................................................................................... 7

      2.3   Steps to manage enquiries, feedback and complaints ......................................... 7

  3.        Classification of enquiries, feedback, and complaints ............................................... 9

      3.1    Definitions ........................................................................................................... 10

      3.2   Complaint levels .................................................................................................. 10

      3.3   Risk assessments ............................................................................................... 12

  4.      Roles and responsibilities ........................................................................................13

      4.1    National Contact Centre ...................................................................................... 13

      4.2   Service Delivery Group ....................................................................................... 13

      4.3   Complaints team ................................................................................................. 14

      4.4   Managers and leaders ........................................................................................ 14

      4.5   Partners in the community .................................................................................. 15

      4.6    Strategic Leadership Team ................................................................................. 16

  5.       Referrals to other organisations ..............................................................................16

      5.1    Enquiries, feedback, and complaints about service providers ............................ 16

      5.2   Serious incidents where abuse, neglect or exploitation is suggested ................. 17

      5.3   Complaints which are outside of the NDIA’s control ........................................... 17

      5.4    External review of how we managed an enquiry, feedback or complaint ........... 18

      5.5    External review of our decisions ......................................................................... 18

  6.       Privacy .....................................................................................................................18

      6.1   Handling of personal information requirements .................................................. 18

      6.2   Authorised representatives and consent requirements ....................................... 19

      6.3   Raising complaints and feedback anonymously ................................................. 19

  7.      Continuous improvement .........................................................................................19

  8.      Process owner and approver ...................................................................................20

  9.      Feedback .................................................................................................................20

  10.     Version change control ............................................................................................20

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1.  Context

1.1  Background

The National Disability Insurance Agency (NDIA) welcomes enquiries, feedback, and
 complaints. We want to provide an excellent service today and in the future. To
 ensure we do this we have a strong focus on listening to people with disability and
 those important to them. We listen to learn from their experiences, whether they are
good or bad. Feedback is a critical part of improving the service we provide.

The NDIA is committed to improving the service we deliver to people with disability
and their families and carers. All NDIA staff and partners in the community have
 equal responsibility to receive and respond to enquiries, feedback, and complaints.
 This means there is no wrong door for an individual to raise an issue or concern with
 us.

We value and respect all feedback. We want people to feel safe and supported to share their views and experiences with us. Our goal is to understand and resolve concerns as quickly as possible. We aim to do this long before they become complaints. Simple enquiries, feedback and complaints are often resolved at first contact.

Our Enquiries, Feedback and Complaints policy sets out what this means for people
who are raising issues and concerns with us.

 This framework guides staff on what this means for us and how we work.

1.2  Purpose

   The framework aims to:

      help us resolve each question, issue, or concern as quickly as possible and
      as close to the desired outcome the person is seeking as possible. (Please
         refer to the definitions for more detail).
      support staff to implement the Enquiries, Feedback and Complaints policy
        (the policy).
      establish principles that align with the Participant Service Charter to guide our
      approach to enquiries, feedback and complaints.
      define steps and timelines about how we manage feedback and complaints
       across NDIA.

1.3  Scope

The framework is for all people who provide a service or perform a function for, or on
 behalf of, the NDIA. This includes NDIA staff, National Contact Centre (NCC) staff
and partners in the community.

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The framework guides our processes for managing feedback and complaints about
 the NDIA’s performance, conduct or processes.

 There are different processes for enquiries that are covered in separate guidance
  material.

The Participant Service Charter sets out timeframes that apply to our processes in
  this framework. It also establishes timings for other issues and concerns that are not
 covered here.

 People may raise issues and concerns with us that are not covered by this
 framework, including:

      Issues and concerns about NDIS providers. These are handled by the NDIS
        Quality and Safeguards Commission.
      Serious incidents of abuse, neglect or exploitation. These are managed in line
        with the Participant Critical Incident framework.
      Concerns raised internally by NDIA staff about unacceptable workplace
       behaviour. These are managed in line with the Safe and Respectful
      Workplace policy and guidance.
      Protected disclosures made in line with the public interest disclosure
          legislation.
      Where someone asks for a review of a decision.
      Complaints that need to be referred to other consumer, government, or state
         authorities to investigate. For example, a complaint about another government
       agency.

 There are other issues that are subject to specific processes. This includes:

      allegations of fraud that must be dealt with under the Commonwealth Fraud
        Control Framework, or
      serious allegations of staff misconduct. These must be dealt with under the
       Public Service Act 1999.

  Staff should follow other relevant guidance and refer people to other organisations
as appropriate in these instances.

2.  Our approach to manage feedback and
   complaints

2.1  Principles

Our approach to managing enquiries, feedback and complaints is:

       Centered on the individual needs of the person raising issues.
       to listen and respond to people who share their feedback to improve the way
     we deliver the NDIS.

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       to help address issues that are raised with us sooner and better.
       to provide a feedback process that is easy to understand and follow.
       to support people to feel safe to share their experiences with us.

 This framework also observes the fundamental guiding principles outlined in the
Commonwealth Ombudsman: Better practice guide to complaint handling (external).
These include fairness, accessibility, efficiency, integration and first contact
 resolution.

  All feedback and complaints must be handled in line with our participant engagement
  principles. These principles are transparent, responsive, respectful, empowering,
and connected. Our principles align with the

        NDIS Participant Service Charter
        National Disability Insurance Scheme Act 2013 (external) (NDIS Act).

  In more detail, our participant engagement principles are:

 Transparent: We will make it simple and clear to raise an enquiry, feedback, or
 complaint. We do this with accessible and well-publicised channels.

  We will publicly publish information and policies about our processes that are
     transparent, clear, accessible, and simple.

  We will be transparent with and outline our feedback and complaints handling
    processes to participants and provide them with the reasons for our decisions.

   There is no wrong door to raise an issue. We will make sure channels into the
  NDIA are well-publicised and accessible.

Responsive: We will consider all enquiries, feedback, and complaints quickly and
  seriously. We will let people know what to expect.

  We will promptly acknowledge every contact and maintain timely communication
     with the individual raising the enquiry, feedback, or complaint.

  We will actively manage people’s expectations for resolution throughout the
    process and provide regular updates.

  We will address enquires, feedback and complaints quickly and seriously in order
     of urgency and risk.

  We will triage enquiries, feedback, and complaints to the right staff for resolution,
   and empower staff to resolve more issues where applicable.

 Respectful: We recognise the safety and rights of people when they raise an issue.
Our knowledgeable and accountable staff will respond to people with empathy and
 understanding.

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  We will recognise the rights and safety of people raising issues in all
    circumstances.

  We will actively listen to people raising issues and take time to fully understand
   them and their circumstances.

  We will listen and respond to people raising issues with empathy, understanding,
   and consideration.

  We will ensure our staff have guidance and training to engage with people in a
      culturally safe, trauma-informed, and accessible way.

  We will ensure people are connected to staff that are helpful and knowledgeable.
     Staff will be accountable and will have the necessary training and authority to
    resolve issues.

Empowering: We encourage and enable people with disability to raise issues with
us directly. We value their experience by learning from it to improve how we do
  things.

  We will ensure that we provide sufficient information, publicly and directly, to
    support people to make the best decisions for themselves.

  We will support people to raise their issues directly with us or with support from
      their representatives.

  We will upskill staff to consistently and accurately categorise feedback and
    complaints to ensure the feedback we receive can be used to improve processes
   and systems.

  We value complaints data and will use it to inform decision making and
    continuous improvement opportunities.

Connected: We will support people to access, engage with and navigate our
 processes. We will support them to get as close to their desired outcome as possible
 while adhering to NDIS legislation and guidelines.

  We will actively engage people raising issues to get them as close as possible to
      their desired outcomes.

  We will engage with community and advocacy services and use them to assist
    people in raising their issues with us.

  We will ensure participants and the public are aware of other government and
   community services and supports they can access.

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2.2  Timeframes

The Participant Service Charter provides clear service standards and timeframes.
  After people contact us, we aim to:

       Acknowledge all contact within 1 day of receipt.
       Contact you within 2 days of acknowledgement.
       Resolve 90% of NDIA managed responses within 21 days of receipt.

We aim to resolve issues and concerns as soon as possible, but some complex issues may take longer than 21 days to address. If the issue will take longer than 21 days staff should contact the person to inform them of the progression and when the issue will likely be resolved.

The following informs how we respond and communicate about enquiries, feedback,
and complaints by:

      Taking immediate action if there is a high or extreme risk identified to the
       person or their situation.
      Keeping people informed about the progress of their enquiry or complaint at
       every stage.
      Publishing regular information on our performance against the Participant
       Service Guarantee through the NDIS Quarterly Report.

2.3  Steps to manage enquiries, feedback and complaints

  All our staff have a role in actively supporting the people they serve to be heard. Our
  staff ensure that any issues raised are understood, acknowledged, and appropriately
 resolved wherever possible.

The steps involved in managing enquiries, feedback and complaints are outlined
 below.

Step 1 - Acknowledge

We will acknowledge contact within 1 day of receiving an enquiry, feedback, or complaint.

Step 2 - Assess and record

When we receive the enquiry, feedback, or complaint, we need to:

      work out how we can answer the enquiry or resolve the feedback or
        complaint.
      record it in our business system.

To do this we will consider:

      the resolution that the person raising the issue is seeking.

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      who we need to work with to help resolve the issue.
       o  check for alerts in the NDIS business system.
       o  determine whether it is an enquiry, feedback, or complaint (see 3.1 for
                further detail).
       o  determine classification level and appropriate way to action, including
          who is best placed to help resolve the issue (see 3.2 for further detail).
       o  consider risks including risk to individual safety (see 3.3 for further
                  detail).
      any accessibility requirements and the person’s preferred communication
      method.
      the sensitivity of the matter, including privacy considerations.

Step 3 – Contact

We will contact people within 2 days to let them know how we are managing their enquiry, feedback, or complaint. People may be contacted by phone or email.

We might ask people for more information to help us better understand the issue and desired resolution.

Step 4 – Resolve or refer

The first staff member who receives the enquiry, feedback or complaint will try to
 address and resolve it.

     If this is not possible, staff should communicate with the person on what we need to
 do and who will contact them next. We need to advise if the issue needs to be
  referred to another business area to be resolved. This may be to the business area
 where the issue first arose or the Complaints teams if it cannot be resolved at level 1
 (see 3.2 for further detail).

We try to help people with most issues the first time they tell us about them. Where there are multiple issues to be investigated, staff should:

        try to resolve what they can.
       only refer what they are unable to resolve.

Step 5 - Communicate

We will make sure we contact the person:

       each time we have an update.
       regularly until we find an answer to their enquiry.
       regularly until we resolve their feedback or complaint as close to their desired
      outcome as possible.

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Step 6 - Respond

We will contact people when we finish managing their enquiry, feedback, or complaint.

     If we need to, we will provide them with more information, explain our decision or
 provide a remedy or apology where appropriate.

Step 7 - Follow-up

   All staff have a responsibility to tell the person about their escalation options. This
  includes within the NDIA or externally if the person is not happy with:

       our decision.
       how we managed the enquiry, feedback, or complaint.

 There may be times where it is appropriate for the review process about our decision
  to run at the same time as a complaint. Staff should advise people of their internal
and external review rights.

A person may be behaving unreasonably and should be managed in line with the
Managing Unreasonable Behaviour policy and associated work practices when they:

      refuse to accept a decision on a matter and consistently raise the same issue.
      make unreasonable demands.
      act violently, vilify others or make threats.

Step 8 - Consider and learn

  After we finish managing the enquiry, feedback or complaint, it is important to record
   all actions, decisions and themes in the relevant business system.

 Regular analysis of the issues raised through enquiries, feedback and complaints
 helps us see if there are any:

      systemic issues we need to address.
      improvements for us to consider.

 This process helps us keep improving how we do things.

3.  Classification of enquiries, feedback, and
   complaints

     It is important for us to classify enquiries, feedback, and complaints. This helps us:

       connect people to the right area to help them with their issue.

       deliver a timely and suitable response.

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       use information to improve our performance and service.

  Enquiries, feedback, and complaints may move between classifications if:

       a person’s situation changes.
       more information emerges during the investigation and resolution process.

The Framework incorporates definitions, levels and uses the Escalation and
  Prioritisation matrix. This allows matters where risks are identified to be escalated as
 needed.

3.1  Definitions

  Enquiries, Feedback and Complaints can be difficult to distinguish and may overlap
  with one another. When we say ‘enquiry’, ‘feedback’ and ‘complaint’ we mean:

 Enquiry: The act of requesting information, knowledge, or action.

 Feedback: Feedback is an observation made by a person or their representative
 about their experience which may take the form of a suggestion, opinion, or
 compliment.

 Complaint: An expression of dissatisfaction indicating an experience with the NDIA,
  or a related entity is displeasing or unacceptable and requires a resolution or
 response.

Key distinguishing factors include:

      A complaint or enquiry needs an intervention or resolution. Feedback only
      needs acknowledgement.
      A complaint is triggered by dissatisfaction or frustration. An enquiry is not.
      An enquiry requires an action or information/knowledge sharing. Feedback
      does not.

3.2  Complaint levels

We classify complaints across three levels. This enables appropriate resolution and reporting.

 Level 1 – issues that can be resolved at first point of contact

These issues or concerns can be resolved by the staff member and or business area
who first receives the enquiry, feedback, or complaint.

They can be resolved by:

       providing information or an explanation.
       acknowledging concerns or apologising.

  All NDIA staff manage Level 1 matters. This includes the National Contact Centre,
 partners in the community and teams within the Service Delivery Group.

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Examples of issues that can be resolved at first point of contact are:

      The issue is straightforward and can be resolved by providing information, an
        explanation, acknowledging the concern and/or providing an apology, if
        appropriate.
      The issue is better dealt with by another organisation and should be referred
       (see 5 for further detail).
      The person does not wish to have the issue progressed further.

 Level 2 – issues that require investigation

These issues or concerns require investigation and/or coordination to resolve.

They can be resolved by:

      providing additional information about a decision, process, or procedure.
      correcting an error.
      providing feedback to our staff about conduct or errors in processes.

They may need input from more than one NDIA area to resolve.

The complaints team will manage these issues and may refer matters to the
 appropriate business areas for management of actions. This may be the business
 areas where the issue first arose. Examples of issues that need investigation and/or
 coordination to resolve can include:

      Completing an action or providing further information or explanation about the
       issue by the responsible business area. An example is providing an
        explanation of decision or delegate action.
      Coordinating actions or information from more than one business area to
        resolve the issue. An example is if the resolution requires input from both
      payments and planning.

 Level 3 – issues that are complex or require formal resolution

These issues are complex or need formal resolution. This may include issues or
 concerns that:

      relate to Administrative Appeals Tribunal matters or need legal advice.
      need external involvement (other consumer bodies or government or state
         authorities, such as state health or justice departments).
      include an allegation such as a breach of the NDIS Act or the APS Code of
       Conduct.
      need a formal response including formal written complaints referred to the
        Minister or members of parliament.
      cover multiple issues raised over an extended period for a participant that
        requires extensive investigation.

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      are high or extreme risk matters and have a high volume of correspondence
      and repeated escalation.

These issues need more detailed or formal investigation. They are managed by the
 Complaints teams with support from relevant business areas.

 Issues may be escalated from level 2 or may be referred directly to level 3 based on
 the nature of the complaint or issues raised.

3.3  Risk assessments

The Escalation and Prioritisation Matrix helps staff to identify enquiries, feedback
and complaints that:

       involve high or extreme risk.
       need a higher priority or escalated response.

The Participant Safeguarding policy (external) outlines the need to take a proactive
and individualised approach to identify and assess risk. This means considering
  intersectionality and the compounding impact of multiple risk factors. For example, if
 there are multiple low risks identified this may mean the overall assessment is high.

Key factors to consider are:

       Risk of harm to the health or well-being of a person including:
       o  family and domestic violence or abuse, including any evidence of prior
             experience of violence, abuse, neglect, or exploitation.
       o  non-domestic violence or abuse (e.g., carer abuse).
       Instability in a person’s accommodation arrangements.
       Instability in a person’s informal support arrangements including:
       o  history of, or susceptibility to financial abuse.
       o  extent of informal and community support networks – for example,
            whether there are independent trusted people to consult with, including
             those who may advocate on the person’s behalf.
       o  participant lives alone.
      Risk associated with the person’s health related supports.
      Risk associated with the availability of plan funds to purchase supports.
      Risk associated with the availability of providers, workers, or other critical
       supports including:
       o  having a sole provider.
       o  low plan use or an inability of the person to effectively use their NDIS
              plan (including thin market issues).

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4.  Roles and responsibilities

 There is no wrong door for people to raise enquiries, feedback, or complaints. All
  staff and partners in the community are responsible for administering this framework.

4.1  National Contact Centre

The National Contact Centre (NCC) is often the first point of contact for enquiries,
 feedback and complaints. This includes issues raised through the NDIS website,
 enquiries@ndis.gov.au and feedback@ndis.gov.au email address, and the NDIS
1800 800 110 phone number.

 The NCC is responsible for:

       Contacting the person via their preferred communication method to
      acknowledge we received their enquiry, feedback, or complaint.
       Assessing risk and recording all enquiries, feedback and complaints received
       through NCC managed channels.
       Attempting to resolve issues or concerns at the first point of contact where
         possible. If this is not possible, the NCC staff member will explain to the
       person their issue or concern has been recorded and the process for it to be
         investigated.
       Gathering more information to support the enquiry, feedback, or complaint
         resolution.
       Referring more complex feedback and complaints to the Complaints team if
        they cannot be resolved at level 1.
       Referring enquiries to relevant business areas in line with enquiry processes
      and procedures if they cannot be resolved at level 1. This includes completing
      a risk assessment (see 3.3 for further detail).

4.2  Service Delivery Group

 Service delivery teams are often the first point of contact for people to raise issues
and concerns. They should try to resolve issues when they are received. Service
  delivery also has an important role to support the resolution or response for more
 complex issues.

 Service delivery teams are responsible for:

       Recording all enquiries, feedback and complaints received directly.
       Attempting to resolve all issues or concerns at the first point of contact where
         possible. If this is not possible, explaining to the person:
        o  that the issue or concern has been recorded.
        o  the process for the issue to be investigated.

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       Referring more complex feedback and complaints to the Complaints team if
        they cannot be resolved at level 1.
       Referring enquiries to relevant business areas in line with enquiry processes
      and procedures if they cannot be resolved at first contact.
       Supporting the resolution by:
        o  gathering more information.
        o  providing planning outcomes/decisions explanations.
        o  correcting process/procedural issues.
        o  communicating with people about their issues and concerns.

4.3  Complaints team

The Complaints team within the NDIA provides specialised support to the Agency.
They manage issues that are complex or need formal resolution.

The Complaints team is responsible for:

       Triaging, investigating, and resolving or responding to feedback and
        complaints in line with this framework. This includes:
        o  coordinating actions to resolve or respond to issues.
        o  communicating with people about their issues and concerns.
        o  written responses.
        o  recording actions and outcomes.
       Managing escalated complaints referred by the NCC.
       Managing feedback and complaints received by NDIA executives. This
        includes NDIA CEO, Board, and other senior executives.
       Managing feedback and complaints received by the Minister.
       Providing a liaison point for external oversight bodies including the
      Commonwealth Ombudsman and NDIS Commission.
       Supporting the Legal service teams on Australian Human Rights Commission
        matters.
       Supporting staff when managing local complaints. This includes:
        o  providing advice.
        o  assisting escalation where needed.
        o  support to identify a complaint, review, or both.
       Managing the participant critical incident process and responding to
          notification of participant critical incidents.

4.4  Managers and leaders

Managers and leaders across the NDIA have an important role in fostering a positive
 feedback and complaint culture. This includes welcoming and viewing all feedback
as an opportunity to improve.

Managers and leaders are responsible for:

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       Supporting staff to resolve enquiries, feedback and complaints as outlined in:
        o  this framework.
        o  the Participant Service Charter.
       Developing staff and improving their capability to manage enquiries,
       feedback, and complaints, and provide a quality service delivery experience.
       Sharing and discussing feedback and complaint data with staff and teams to
        support a better understanding about:
        o  the themes and systemic issues.
        o how this links to improving participant’s services.
       Working with partners in the community to support the NDIS Feedback and
       Complaints framework application.

4.5  Partners in the community

 Following the same principles expected of NDIA staff, all partners in the community
 are responsible for:

      Recording all enquiries, feedback and complaints received directly.
      Attempting to resolve all issues or concerns at the first point of contact where
        possible. If this is not possible, explaining to the person:
       o  that their issue or concern has been recorded.
       o  the process for the issue to be investigated.

Where enquiries, feedback and complaints are received by:

      partners in the community and are about staff performing scheme related
         functions, the partners in the community will investigate the issues or
       concerns using their internal feedback and complaint management
       processes. All matters are to be recorded in the NDIS business system.
      the NDIA and are about a partner in the community, staff should record them
          in the NDIS business system and refer them to the relevant partner
        organisation to manage.

 Matters should only be referred to the Complaints team to manage if they are
assessed as level 2 or 3 (see 3.2 for further detail). This may include issues about a
 partner in the community, NDIA performance, conduct or procedure.

 Partners in the community must help any NDIA investigation when we need more
 information.

As mandatory reporters, Partners in the community need to follow the relevant
 reportable incident protocols for each state/territory. Protected information obtained
 from the NDIA is an exception.

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4.6  Strategic Leadership Team

The NDIA Strategic Leadership Team (SLT) and Senior Executive Service (SES)
 lead the positive complaint and feedback culture. They create and support the
 environment where continuous improvement is an everyday practice for all agency
   staff. This includes the willingness to review practices and explore new ways of
 doing our work.

The SLT members are accountable for their respective business areas. This
 includes managing issues in line with the timelines and practices contained in:

      The Participant Service Charter.
       Ministerial Support Service Charter and other parliamentary guidance.
      Commonwealth Ombudsman guidance.
      NDIS Commission guidance.

5.  Referrals to other organisations

 There are times when the NDIA cannot resolve an enquiry, feedback, or complaint.
 This may be due to:

       the issue out of the scope for NDIA.
       multiple contacts about the same issue which has not resulted in a
         satisfactory resolution.

  In these instances, staff should tell people about other external bodies who may be
  able to help them with their issue or concern.

5.1  Enquiries, feedback, and complaints about service providers

 Service providers are independent organisations. The NDIA is not responsible for
 managing enquiries, feedback or complaints relating to service providers. Where an
  enquiry, feedback or complaint is received by the NDIA about a service provider,
   staff should:

       record it in the NDIS business system.
       advise the person to follow the provider’s complaint and feedback processes
           in the first instance.

      If this has already been done, the person should be told to contact the NDIS Quality
 and Safeguards Commission (NDIS Commission).

The NDIS Commission regulates the quality and safety of supports and services
  delivered by NDIS providers.

The NDIS Commission takes complaints about provider services that were not:

       provided in a safe and respectful way.

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       delivered to an appropriate standard.

 People can contact the NDIS Commission by:

        calling the NDIS Commission on 1800 035 544.
        visiting the NDIS Commission website.

We have a duty of care to maintain participants’ safety. This may result in a review of their plan or supports, or the NDIS Commission may review the service provider’s registration.

The NDIA has a Complaints Handling and Reportable Incidents Arrangements
 Operational Protocol with the NDIS Commission. In some cases, we will transfer
 complaints or collaborate on investigations and resolutions. This may happen when
 a complaint is about a provider or if the issue affects the supports available to a
NDIS participant.

The Complaints team handle these issues under the Complaints Handling and
 Reportable Incidents Arrangements Operational Protocol.

5.2  Serious incidents where abuse, neglect or exploitation is
    suggested

   All NDIA staff must report concerns about abuse, neglect, and exploitation to
  appropriate authorities where:

       these are observed.
       suspected.
       reported through interactions with participants and service providers.

 The Participant Critical Incident Framework and Practice guide outlines this
  process.

The NDIA Participant Critical Incident team supports the handling of these incidents
   in line with the Complaints Handling and Reportable Incidents Arrangements
 Operational Protocol.

Where staff have concerns that a person is at immediate risk and they require an
 emergency response, staff may need to contact emergency services on “000”.
Where possible, staff should discuss this with their line manager before contacting
 emergency services.

5.3  Complaints which are outside of the NDIA’s control

Some feedback and complaints need to be referred to other consumer bodies,
 government, or state authorities to investigate. For example, this could be an issue
 about another government agency.

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 Complaints to the Complaints Resolution and Referral Service (external) can be
made by clients of services funded by the Department of Social Services (DSS)
 under the Disability Services Act (1986). These services include:

       Disability Employment Services (DES).
      Australian Disability Enterprises (ADEs).
      Advocacy Services (funded by Department of Social Services).

5.4  External review of how we managed an enquiry, feedback or
    complaint

     If people are not happy with how we managed their enquiry, feedback, or complaint
 they can contact the Commonwealth Ombudsman by:

        calling the office of the Ombudsman on 1300 362 072.
        visiting the Ombudsman website.

5.5  External review of our decisions

     If people are not happy with our decision, they may consider options to review our
 decision.

     If a person is not satisfied with the outcome of an internal review, they can apply for
a review by the Administrative Appeals Tribunal (AAT). This is an independent
  tribunal.

 People cannot ask the AAT to review a ‘reviewable decision’ until the decision has
been internally reviewed by the NDIA.

 Information about the AAT review process can be found at AAT: National Disability
Insurance Scheme applicants website or by calling 1300 366 700.

6.  Privacy

6.1  Handling of personal information requirements

  All enquiries, feedback and complaints must be managed in line with the NDIA’s
 Privacy policy. All staff must comply with their obligations under the:

       Privacy Act 1988 (Cth).
       National Disability Insurance Scheme Act 2013 (Cth).

  This protects all records with personal information from unauthorised access,
 misuse, interference, loss, or disclosure.

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NDIA staff and partners in the community must follow the Your Privacy and
 Information Guideline when handling personal information within an enquiry,
 feedback or a complaint.

6.2  Authorised representatives and consent requirements

  Staff must ensure that the person raising the issue or concern is:

       an authorised representative, or
       has the relevant consent to act on behalf of the applicant or participant, or
       has the relevant consent to get information about the participant in relation to
        the issue being raised.

More information about consent can be found in the Check consent, nominee, child
 representative or self-representation authorities (Knowledge Article).

     It is important to tell people that while some issues can still be progressed without
 consent, it will limit the information that can be given to the person raising the issue
 or concern.

6.3  Raising complaints and feedback anonymously

     It is critical that people feel safe to raise issues with the NDIA. We must ensure
 people know and understand there will be no negative consequences if they choose
  to raise a complaint with us. In some instances, people will choose to remain
anonymous.

We respect people’s right to make anonymous complaints and feedback. Sometimes to investigate an issue or concern we may need to establish and disclose a person’s identity to the NDIA staff member who is resolving the issue.

Where a person expresses their wish to remain anonymous, we must tell them that
 the NDIA may not be able to fully respond to their complaint without establishing
  their identity.

7.  Continuous improvement

 Enquiries, complaints, and feedback provide an opportunity to learn from consumers
and enhance business practices and processes. Continuous improvement is an
 ongoing cycle of identifying and acting on opportunities to improve.

The NDIA improves complaints reporting by implementing:

       consistent work practices.
       consistent records management across the NDIA.

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This enhances our ability to identify systemic issues.

Regular analysis of complaints and feedback helps us develop training material to support staff and improve service delivery. Suggestions and ideas from staff are an

important part of improving the way we deliver our services.

  1. Process owner and approver

Branch Manager — Complaints Management and Freedom of Information.

  1. Feedback

If you have any feedback about this framework, please email Complaints Continuous Improvement Team. In your email remember to include the title of the document you

are referring to and describe your suggestion or issue concisely.

  1. Version change control
Version No Amended by Brief Description of Change: Status Date
7.0 TEMS907 Corrected link to Knowledge Article APPROVED 2024-05-22
6.0 TEmg07 Updates to links and email addresses APPROVED 2024-05-21
5.0 LS0056 Update to align with new public facing policy and feedback from SLT APPROVED 2023-12-07
4.0 EGL679 Update to align with new public facing policy and feedback from SLT DRAFT 2023-12-06
3.0 JPO467 Update to align with new public facing policy DRAFT 2023-09-23
2.0 SW0065 Update to guidance. APPROVED 2020-06-02

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