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Standard Operating Procedure

For Internal Use Only

The contents of this document are OFFICIAL.

Resolving Complaints

This Standard Operating Procedure (SOP) supports Complaints Officers to manage, resolve and finalise complaints referred to the Complaints and Participant Incident Team (CPIT).

Note: The term Complaints Officers used in this SOP also refers to Senior Complaints Officers.

1. Recent updates

Date	What’s changed
Jan 2023	SOP update to include information/process on RFAs to the NDIS Fraud team.
Feb 2023	Updated CPIT Management and Recording of Multi-channel Complaints.
April 2023	Updated section 6 Initial Contact, 6.1Contact considerations to include updated CSN participant process.
May 2023	Formatting updated. Updated Risk Assessment process- removed outdated CPIT risk escalation matrix (timeframes removed).
August 2023	Update to General considerations to include clarification between Complaints and Oversight Template Guide and Guide to Interactions in the NDIS Business System
October 2023	Updated to include new process for ND and HAL decision explanation requests.

Added Section 7.1 Complaints requiring an explanation from National Delivery or the Home & Living team regarding a decision. Inclusive of link to SOP_ExplanationOfADecision.docx (ndia.gov.au) |

2. Checklist

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Topic	Checklist
Pre-requisites	Q A complaint has been received, risk-level assessed, entered into the Business System (CRM and allocated to Complaints Officer.
Q The 2 day contact has been completed via email or phone.
Q You have read Standard Operating Procedure - Allocating and Receiving a Complaint.
Q Understanding of the Complaints and Feedback Framework
Q Access to CRM business system and agency guidance materials.
Actions	Q General considerations
Q 4 Procedure
Q 4.1 Consent and privacy
Q 4.2 Complaint assignment in CRM
Q 4.3 Preliminary investigation
Q 5 Managing unreasonable conduct and strategies for managing them
Q 5.1 Multiple complaints about the same issue by same complainant
Q 5.2 Managing unreasonable behaviour
Q 6 Initial Contact
Q 6.1 Contact Considerations
Q 6.2 SMS Alert
Q 6.3 Contact attempts
Q 7 Request for Action
Q 7.1 Complaints requiring an explanation from National Delivery or the Home & Living team regarding a decision
Q 7.2 Agency and Partner staff complaints
Q 7.3 Model Litigant Obligations (MLO) complaints
Q 7.4 Create and assign Request for Action in CRM
Q 8 Payment Enquiries
Q 9 Follow-up process
Q 10 Closing complaint item
Q 11 Related procedures and resources
Q APPENDIX A – Resolving Complaints Workflow
Q APPENDIX B – Complaints Risk Escalation Matrix

3. General Considerations

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Standard Operating Procedure

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The National Disability Insurance Agency (NDIA) welcomes feedback, including complaints, compliments and suggestions.

The NDIA is committed to operating in line with the Participant Service Charter. To support this, we listen to NDIS participants, their representatives and those delivering the Scheme to learn from their experience, positive or negative.

CPIT has their own template guide to assist you all with managing the end-to-end complaint process referenced through this document. All staff should also consider the following document when creating interactions in the NDIS Business system, CRM, as it is an Agency endorsed resource Guide to Interactions in the NDIS Business System .

4. Procedure

4.1 Consent and Privacy

Complaints Officers must ensure that the complainant has the relevant consent to act on behalf of the applicant or participant, or to be provided with information about the participant in relation to the complaint.

Consent can be viewed under Details tile in participant record. At times, Complaints Officers may need to check inbound Documents and Attachments to confirm whether consent was provided and not recorded for the participant. If consent is confirmed from the documents, Complaints Officers must record/update consent for the participant in CRM.

More information about consent can be found in the Check third party consent or authority SOP.

If the complainant is not the participant, Complaints Officers must seek the participant’s consent via phone (or email where phone is not the appropriate option) where required. Ensure consent details are clearly recorded in an interaction using the Verbal Consent Obtained interaction template. Verbal consent is single use only, do not record ongoing verbal consent in CRM.

Note: Complaints Officers can progress complaints where participant’s consent is already recorded in CRM without having to seek consent again. For Level 3 complaints, follow steps as per relevant team/agency.

For Ministerial and MaSCO complaints, consent is implied if correspondence is sent from participant/nominee to the Minister or MP. However, if the complainant is a third party with no consent provided, Complaints Officers must call the participant to seek consent.

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Standard Operating Procedure

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For Ombudsman investigations, the Ombudsman Act 1976 provides consent for the Agency to share information in relation to Section 7a or Section 8 investigations. If the Ombudsman is investigating a third-party complaint – consent details should be noted in the response.

For NDIS Quality and Safeguards Commission (NDIS Commission), the Complaints Handling and Reportable Incidents Arrangements Operational protocol agreement between the two agencies allows sharing of information under sections 60, 66, 67A and 67E of the NDIS Act.

For NSW Ageing and Disability Commission complaints, information can be shared if the request meets the requirement of sections 60 and/or 66 of the NDIS Act.

Note: In some cases a complaint can be progressed without consent. We can progress such complaints but are limited in the information we provide to the complainant. Examples include complaints about processes or staff, LAC, Provider etc.

Complaints Officers should take note of any special considerations that apply to the complaint on the My Requests work item, for example if the complainant has asked for their identity to be withheld from others, or if there is sensitive or confidential information that needs to be safeguarded.

4.2 Complaint assignment in CRM

Before conducting preliminary investigation of the complaint assigned to you, navigate to the Outcome tab within the My Requests work item to ensure the Status field is In Progress. To update the Status field, click Edit and select the Status field to In Progress from the drop-down menu.

Check that the complaint has been entered in CRM accurately using the correct practice as per Sections 6 to 13 of the Practice Guide – Data Dictionary for My Customer Requests App.

Add a note to Outcome Notes as follows: <dd/mm/yyyy> Investigation commenced by . Then press Submit.

Prior to making any contact with the complainant, review CRM My Requests items to determine whether the same complaint is already being managed by another Complaints Officer or team. If so:

for Level 2 complaints, the Complaints Officer managing the earlier complaint will manage both complaints. This also applies when a complaint has been closed within the previous 2 weeks or there are sensitivities around contact by a new Complaints Officer. Complaints Officers to use Reassigning Complaint email template in Complaints and Oversight Template Guide for reassignment.

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Standard Operating Procedure

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If the complaint is received via feedback or other channels, an auto-acknowledgement will be generated by NCC. NCC will be likely to react first and follow through with the 2-day acknowledgement.

If the complaint is then also received by all (or some) of the L3 spaces (except Oversight Stream) staff will then follow the current process (as per “Actioning and Investigating a Complaint” SOP) to determine who takes the lead.

A complaint will be created in CRM by all teams that have a deliverable i.e. Exec – CEO Summary, Min Formal response. Once it is determined that a Level 3 complaints officer is to take carriage of the complaint handling, Complaints Res will close their complaint in CRM as a duplicate.

The lead team will be required to complete the 2-day contact on behalf of all other streams that have received the complaint.

All receiving teams are required to update CRM to reflect that the 2-day contact process has been completed.

The lead team is responsible to provide required update(s) to all other receiving teams to enable them to meet their reporting obligations (Informal Min have the most with weekly updates to the MO).

Any updates are required to be recorded in the outcomes tab – in the same way as if the team was managing the complaint.

Lead team provides final update that allows final reporting/responses to be drafted and the complaints outcome is to be updated and all complaints can be closed.

Where there is a Level 3 complaint managed by MaSCO, Ministerial, Oversight or Executive Complaints team, the relevant L3 Complaints Officer will manage both the L3 and L2 complaints together. This prevents duplication of effort and/or confusion. Complaints Officers must communicate with one another to get an agreement on the person responsible to take carriage of the complaint. Ensure this is documented in the complaint’s interaction.

If the Executive team assesses the complaint received by them as a low risk, the team creates the complaint as Level 2 in CRM, acknowledges the complaint and makes a note in the Outcome tile that mentions to progress the complaint as a Level 2 complaint. This then gets allocated to Complaints Resolution team as per Standard Operating Procedure - Allocating and Receiving a Complaint.

For duplicate Ministerial complaints, and Ombudsman Section 7A and Section 8 investigations: Wherever possible, any new complaints for relevant stream will be assigned to the Complaints Officer that dealt with the previous complaint in that team.

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Standard Operating Procedure

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For duplicate MaSCO complaints: Any new complaint is assigned to the original Complaints Officer within six weeks of previous complaint closure.

Complaint reassignment process is as follows:

Advise the relevant Complaints Officer of the duplicate/new complaint, add an interaction as per Complaints Resolution and Oversight Template Guide and reassign the My Requests work item to the relevant Complaints Officer in CRM. Seek advice from Senior Complaints Officer/ Team leader when unsure.

If there are sensitivities around contact from a new Complaints Officer, discuss reassignment with the previous Complaints Officer. If reassignment is agreed, add an interaction as per Complaints Resolution and Oversight Template Guide and reassign to previous Complaints Officer.

4.3 Preliminary Investigation

On accessing the participant record in the business system – ensure that you read all alerts and note any that are relevant for managing the complaint (i.e. communication requirements – font type/size, translation, etc.). Refer to View or edit an alert SOP to end date an alert that is clearly outdated. Where a participant has restricted access, contact your Assistant Director to obtain time-limited access to the participant record to resolve the complaint.

4.3.1 Identify key issues and review complaint risk

To guide resolution of the complaint, Complaints Officers should identify the key issues and review risk level of the complaint to ensure it is in line with the evidence presented.

This includes identifying the specific issues the complainant has raised, confirming the risk by referring to Complaints Risk Escalation Matrix and determining whether the investigation should be limited to addressing an individual issue or is of a more general nature requiring broader consideration.

Note: Complaints Officers must prioritise contact for complaints that are identified as High/Extreme risks to the participant/Agency.

4.3.2 Related Parties

Check Related Parties under Categorisation sub-tile to confirm the correct participant is attached to the complaint. Where a complaint is made by a participant their details should be recorded under Personal Information in the Overview sub-tile of the complaint record. Where someone other than the participant has made a complaint then participant information should be recorded under Related Parties. Adding participant under Related Parties allows the complaint to be viewed in participant record in CRM as well as in My Participant portal.

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Note: Only one related party should be added per complaint. If a complaint is from a third party about a participant and relates to fraud or privacy or any other sensitive matter, seek advice from your Senior Complaints Officer/Team leader prior to adding the participant details under Related Parties.

4.3.3 Review background and chronology of actions

Investigate the background and chronology through CRM and other sources. Search for information in CRM to establish an understanding of events. This may include interactions, attachments, planning/budget and payment areas, My Feedback items, or My Request items. It is important to pay particular attention to any actions prior to, and following, the complaint being made.

4.3.4 Research relevant processes

If you are unfamiliar with the issue or work practices, research the process or situation in order to enhance your understanding. This can be done through reading the relevant guidance materials (SOPs, Practice Guidance, Disability Snapshots, Legislation, Rules, and Our Guidelines etc.).

Where you require assistance, seek technical advice from a Senior Complaints Officer (for Level 2 complaints) or a Senior Complaints Officer/Assistant Director (for Level 3 complaints).

4.3.5 Determine action/s required to resolve complaint

Action to resolve the complaint may include:

• an explanation of a decision made based on information held in CRM,
• an apology to the complainant, and/or
• further action by a relevant business area.

Where further information or action is required from the business area, the Complaints Officer may issue a Request for Action (RFA) to the relevant business area. Refer to the section 4.5 - Request for Action for procedure.

A Payment Enquiry (PE) may be required for payment related complaints. Refer to section 4.6 - Payment Enquiries for more details.

5. Managing unreasonable conduct and strategies for managing them

5.1 Multiple complaints about the same issue by same complainant

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Standard Operating Procedure

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When there have been multiple separate complaints from the same complainant regarding a particular issue, and it is evident from previous complaints that the same outcome has been provided at least twice previously. This includes where complainant have been persistent and do not accept the complaint is closed, re-frame an old complaint, persevere obstinately with an argument, continue to phone, or contact the NDIA after matter is closed. Complaints Officers to follow a two-stage management process.

Stage 1: Restate previous complaints resolution outcomes.

• Before contacting the participant make sure you have investigated CRM to check all alerts and no one else is actively managing the same complaint across all CPIT streams.
• Using the Managing Repeat Complainants template in Complaints Resolution and Oversight Template Guide gather the repeat complaint information including the previous Complaint Officer name/s, dates of previous responses and issue/s outcome.
• Thoroughly investigate/review the previous complaints received and complaint outcomes to ensure that the complaint issues were correctly identified and actioned appropriately.
• Depending upon preferred method of contact, use the Managing Repeat Complainants template in Guide to guide the conversation. A written response using the template should be sent immediately after the phone conversation.

Stage 2: Restricting communications when addressing resolved complaints.

Complaint Officers must discuss these situations with their Team Leader/Assistant Director and obtain their written endorsement prior to implementing this stage.

Where repeated complaints and/or unreasonable persistence continues and it is evident from previous complaints that the same outcome has been provided at least twice before, restrictions may be applied to the issues the complainant can raise with the CPIT.

Restrictions include CPIT will not investigate the complaint further, an unproductive phone call will be terminated or no further correspondence on the complaint will be acknowledged and/or answered. Complaints Officers will read and file complaint without any further action.

Such decisions should be made at Assistant Director/Director level. A complainant should be advised in writing of the decision and the options for reviewing its appropriateness.

An email template outlining the restriction is provided in the Complaints Resolution and Oversight Template Guide.

5.2 Managing unreasonable behaviour

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Standard Operating Procedure

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Unreasonable behaviour includes:

• unreasonable demands—raising issues beyond the NDIA’s responsibility, asking for a remedy that is impractical or disproportionate, insisting that more time be spent on a complaint than is warranted, insisting on speaking to the Leadership team, directing the Complaints Officer on how to handle the complaint.
• unreasonable lack of cooperation—unnecessary presentation of a large quantity of material such as emails and documents, failing to provide key documents, constantly re-defining a complaint, dishonestly presenting the facts.
• unreasonable arguments—exaggerating issues, holding irrational beliefs, being obsessed with irrelevancies or trivialities, refusing to consider counter-arguments, being guided by conspiracy theories.
• unreasonable behaviour—threatening violence, abusing Complaints Officers/ NDIA staff, being rude or aggressive, threatening self-harm. Note threats of self-harm by the NDIS participant will require Complaints Officer to follow the Participant Critical Incident (PCI) process.

5.2.1 Strategies to manage unreasonable behaviour

If the complainant exhibits unreasonable behaviour and is not responsive to staff’s warning/request to stop the behaviour we will provide them with a formal warning about their conduct which is available in the Complaints Resolution and Oversight Template Guide

A complainant can be told that a telephone call will be terminated unless more moderate language is used, that threats are unacceptable and may be reported to the police, that rude and intemperate communication may not be answered or may be returned.

Where unreasonable behaviour by the complainant continues, restrictions may be applied to the issues the complainant can raise with the CPIT. Restrictions may include limiting investigation to issues that are within the scope of the NDIS, and by whom, when and how the communication will occur between the complainant and the NDIA. Depending on the type of restriction we may place a limit on telephone calls/ written communications e.g. once every month, after which it can be reviewed based on complainant’s conduct.

When restrictions are applied, Complaints Officers must add an Alert to Participant’s CRM record to advice type and duration of restriction applied and the authorising Complaints Director’s details.

Templates for these communications are available in the Complaints Resolution and Oversight Template Guide.

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Standard Operating Procedure

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Complaints staff should debrief after incidents of unreasonable behaviour. This will assist the staff member to share detail of the incident and maintain their confidence and build resilience by reversing/minimizing the negative effects of the experience. Discuss/debrief with your Team Leader/Assistance Director for further support.

If the complainant is showing signs of escalated and/or abusive behaviour, verbal or written, including threats of self-harm or harm to others refer to Complaints Officers should refer to the following resources available on the intranet:

• Managing Unreasonable Behaviour - Guideline - final.pdf (ndia.gov.au).
• De-escalation Techniques Flow Chart (pdf 57KB)
• Managing unreasonable behaviour – call handling techniques
• Complete LEAP CPIT – Managing Unreasonable Behaviour (MUB) Virtual Sessions

6. Initial Contact

6.1 Contact Considerations

Prior to contacting the complainant that is a third party, ensure consent or authority is established as per section 4.1.

Check the Details tab in the business system and note the following:

• Check Communication Details to understand the participant’s preferred communication method and note any additional communication requirements such as interpreter;
• Check Correspondence Details to note any additional correspondence requirements such as font type and/or size for written correspondence.

Note: Where Letter/Post is the preferred communication channel and an email address is available, then email the participant; if no email address is listed, call the participant on the phone number listed.

Where the complainant is a third party and no correspondence preference is recorded, utilise contact details available in the complaint. For Ministerial or MaSCO third party complaints, seek complainant’s contact details from Minister/MP’s Office as necessary to initiate contact.

Note: For most Level 3 complaints including MaSCO, MP, Ombudsman, and the NDIS Commission, email is the preferred communication channel.

Note: Where a CSN participant has an alert on file regarding a communication plan and a complaint has been submitted. The Complaints Officer is to refer to the Request for Action

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Standard Operating Procedure

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contact assignment list and forward a Request for Action (RFA) to the CSN team seeking guidance on their communication prior to contacting the participant.

See alert example below:

Advise ‘One Main Contact’	Communication Letter with expectations issued 3 February 2023 via SC - Participant to be supported during meetings and to connect with his SC in first instance with any queries.

6.2 SMS Alert

For Level 2 complaints, it is mandatory to send an SMS alert (where mobile details are available) prior to attempting contact with the complainant. This advises the complainant of your intention to attempt contact and the expected timeframe. An SMS should be sent from your MS Outlook using the SMS Email Template in the Complaints Resolution and Oversight Template Guide. The SMS alert is to be forwarded at least 15-30 minute prior to making the actual phone call to allow the complainant time to prepare for your phone call.

Update CRM immediately using the SMS prior to Contact Attempt by Phone interaction template or the SMS post Contact Attempt by Email to ensure that the complainant can verify that contact was made by the NDIA and was not a fraudulent call.

Once contact is established you are not required to send the SMS alert for subsequent phone calls with the complainant.

You may choose to send the SMS alert for follow up conversations however is it not mandatory to do so. Refer to Contact attempts section 6.3 to comply with the number of contact attempts required prior to closing the complaint.

If you have been unsuccessful in contacting the complainant on your third attempt and:

• have been successful in progressing their complaint, send them an email response regarding progress of their complaint followed by an SMS advising the complainant to check their email; or
• have not been able to progress their complaint, send a closure email response followed by an SMS advising the complainant to check their email.

Level 3 complaints streams may have a different process. Refer to the relevant stream SOP for SMS processes.

Note: Do not edit the templates as they are the approved NDIA SMS alerts.

6.3 Contact attempts

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Standard Operating Procedure

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Attempt contact via participant’s preferred communication channel – phone or email.

Record contact attempts in interactions linked to My Requests work item. Use Complaints Resolution and Oversight Template Guide to record interactions and emails.

Complaints Officers must make a total of three (3) contact attempts (or more for some teams) at different times on at least two different days using the complainant’s preferred contact method and at least one other contact method. For example,

• if the preferred contact method is phone, try to contact the participant twice by phone and also try to make contact by email once; or
• if the preferred contact method is email, try to contact the participant twice by email and also try to make contact by phone once.

If you reach voicemail where the person identifies themselves, leave a brief message with the complaint number requesting that they contact the NDIA on 1800 800 110.

At times the Complaints Officer may make two calls within minutes to allow the participant time to mobilise to the phone. This is considered one attempt.

Record details of the contact in interaction linked to My Requests work item.

If contact cannot be established email complainant to advise the next steps. If there is sufficient information available to action the complaint, then progress it accordingly. If not, see Unable to Contact Section 6.3.2 procedure.

6.3.1 When contact is established

Where contact is successful, introduce yourself as the Complaints Officer who will be working on the complaint. Verify the identity of the person you are calling using the appropriate procedure from SOP – Record and verify identity for an individual, or SOP – Verify identity for a third party organisation and SOP – Record third party consent.

Ensure your understanding of the complaint and key issues to be addressed is accurate.

Confirm the outcome complainant is seeking. Seek additional information if required.

Record details of the contact in interaction linked to My Requests work item.

Interactions must be recorded for all conversations or email communications with the complainant. This is particularly important on closure of a complaint item, to ensure that there is a record that the complainant understands and is aware of the complaint closure.

Interactions must be created from a participant or provider’s CRM record and linked to the complaint. This ensures that the interaction is visible in the Interactions tile as well as within the complaint. For further information on Interactions, refer to Guide to Interactions in the NDIS Business System on the intranet.

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Standard Operating Procedure

For Internal Use Only

For very sensitive complaints, create interactions within the complaint in My Request tile. This will not be visible from the interactions tile, but only on accessing the specific complaint record. Go to the Interactions sub-tile within the complaint then click Edit and select Add.

While working on a complaint, Complaints Officers may encounter circumstances or obtain information about allegations that meet the criteria of a Participant Critical Incident (PCI). The reporting party does not need to be authorised on the participant’s plan for them to report a PCI.

The PCI team does not contact complainants or manage complaints. Complaints Officers will follow the complaints process to resolve the complaint while the PCI team manages the Participant Critical Incident elements.

Note: Complaints Officers are to use the following email inbox to send emails to external stakeholders including participants, nominees, and other agencies:

• redacted: s47E(d) - certain operations of agencies
• All other – redacted: s47E(d) - certain operations of agencies

6.3.2 Unable to Contact (UTC)

Following the third unsuccessful contact attempt, send a final email to the complainant using the Unable to Contact template (in Complaints Resolution and Oversight Template Guide) advising of the contacts attempts, and further steps – i.e. either progressing the complaint based on available information or that the complaint will now be closed due to inability to establish contact to confirm details of the complaint.

Add an interaction linked to My Requests work item with a copy of the email sent and where complaint cannot be progressed, update the Status to Closed.

7. Request for Action

A Request for Action (RFA) is a formal request for information or action from another NDIA business area (or areas) to support resolution of a complaint.

A RFA must only be issued when information is not available or accessible on the participant’s record, or action is required that cannot be undertaken by the CPIT. If a Complaints Officer is unsure about the use of an RFA – consult a Senior Complaints Officer for advice.

Endorsement by a Senior Complaints Officer/ Team Leader is required to issue RFAs for all Level 2 complaints. Complaints Officers will seek endorsement via email using the RFA Endorsement template in Complaints Resolution and Oversight Template Guide. Senior Complaints Officers/Team Leader will provide a written response to the Complaints Officer.

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Standard Operating Procedure

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NB – endorsement not required for L3 complaint RFAs.

The RFA must include clear information to enable the receiving business area to take appropriate action. The action required may be:

• provision of further information to CPIT to resolve the complaint

• contact participant and complainant to provide explanation or advise of action.

  Note Where a complainant requires an explanation from National Delivery or the Home & Living team regarding a decision made as part of the complaint resolution this request should not be sent via the RFA process and instead has a standalone process please refer to the: SOP_ExplanationOfADecision.docx (ndia.gov.au)

• action on the record to correct or update information.

Multiple RFAs can be issued if information or action is required from more than one business area.

RFAs are created either on-system (CRM) or off-system (manual). This is dependent on whether the relevant business area has access to a CRM inbox.

Note: When sending RFAs to National Delivery, click on the Details tile in participant record and under Addresses check participant’s home address. This ensures that you are sending the RFA to the right National Delivery team.

7.1 Complaints requiring an explanation from National Delivery or the Home & Living team regarding a decision

Where a complainant requires an explanation from National Delivery or the Home & Living team regarding a decision made as part of the complaint resolution an interaction is to be created using the request for explanation of a decision template housed in the Complaints Resolution and Oversights Template Guide.

The open interaction is then forwarded to:

• National Delivery Return to SDP inbox, in the approving delegate’s jurisdiction for allocation to the delegate.
• Assign any plans with a home and living decision to Operations and Housing Support inbox ‘CR OAHS HAL RTS’

For further information see SOP_ExplanationOfADecision.docx (ndia.gov.au).

7.2 Agency and Partner staff complaints

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Standard Operating Procedure

For Internal Use Only

For privacy, send all staff complaints except for LAC and EC Partners via email to the staff member’s line manager. Line manager can be identified using Organisation tab in MS Teams. Make a note in the Outcomes tile to mention staff complaint emailed to staff’s line manager for further action. Do not attach email in the Documents tile under participant record or in Attachments sub-tile under the complaint. If a staff complaint requires an action for resolution, then follow the steps to create the relevant RFA along with providing feedback to staff member’s line manager via email.

For all partner staff complaints including LAC and EC Partners, send an email to Partner Performance team requesting their assistance to resolve the complaint. Direct contact with partners including LACs is undertaken by Partner Performance team. If a complaint requires a further action to be undertaken by Partners, then use the Sending an off-system RFA Section 7.3.2 to send feedback about the staff along with action required for the complaint.

7.3 Model Litigant Obligations (MLO) complaints

Under the Legal Services Directions Act 2017 (Cth) we have an obligation to act as a Model Litigant. This means that in handling claims and litigation, brought by or against us, we are required to act with complete propriety, fairness and in accordance with the highest professional standards.

MLO complaints received by the CPIT can be referred to the Legal Services, Releases and Resolution Team (R&R) using the Manual RFA Template available in Complaints Resolution and Oversight Template Guide via email at redacted: s47E(d) - certain operations of agencies . The R&R Team will conduct an initial review within 2 business days to determine whether the complaint meets the minimum requirements for further investigation of the MLO.

For complaints that do not meet the MLO minimum requirements for further investigation, the R&R Team will refer the matter back to the CPIT Complaints Officer to manage. Where the MLO’s in question are specifically named and the minimum requirements are not met, R&R will provide an email on a case-by-case basis to assist Complaints Officers to respond back to the complainant.

Note: Email from the R&R Team is for internal use only and must be used to inform your response. Do not forward to the complainant or external stakeholders.

Where the MLO minimum requirement is met the R&R Team will commence an investigation and provide the Complaints Officer with proposed holding lines to respond to the complainant on a case-by-case basis.

Where R&R Team have not provided a response prior to complaint closure date, Complaints Officers must record a follow-up interaction BEFORE closing the complaint item.

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When the review has been concluded the R&R Team will provide legal advice/proposed response to the Internal Reviews and Complaints Branch Manager be sent to the complainant.

7.4 Create and assign Request for Action in CRM

Identify the correct CRM inbox to assign the RFA to via the Request for Action Assignment Contacts List available under resources on the CPIT intranet page. If the business area responsible for RFA response does not have a CRM inbox, please follow the steps at section Sending an off-system RFA Section 7.3.2.

Follow the steps in Complaints Resolution and Oversight Template Guide on how to create an RFA in CRM.

The response time for an RFA will generally be 5 business days. This allows the relevant business area to consider the request and provide a response on action taken, or to be taken, to assist in resolving the complaint. Where there are circumstances that warrant a response in a shorter timeframe, this should be raised with the Senior Complaints Officer/Team Leader during the endorsement process (for Level 2) or applied as necessary for Level 3 streams.

7.4.1 RFAs for the NDIS Fraud Team

RFAs to the NDIS Fraud team are made by completing a manual RFA using the Fraud Reporting RFA template available in Complaints Resolution and Oversight Template Guide. The only response we request is a Case ID number for the complaint and no other information such as actions taken/next steps by the Fraud team. Follow the steps in 4.5.4 Sending an Off-system RFA to send RFAs to the Fraud team.

Once response is received, attach copy of response email to the Complaint and contact Complainant to provide Case ID number. Explain to the complainant that the matter has been handed over to the NDIS Fraud Team and they may not receive a response due to complexities or Privacy concerns, however if they have additional information to provide, they should contact the Fraud Team directly on 1800 650 717 or email fraudreporting@ndis.gov.au.

Close the complaint after providing the case ID reference number to the complainant.

Note: RFAs for PCI and Australian Human Rights Commission (AHRC) complaints are not recorded in interactions or in the Business System. Please refer to Participant Critical Incidents page, Participant Critical Incident Framework and Managing AHRC Complaint SOP for further information.

7.4.2 Sending an off-system RFA

When there is no CRM inbox, you will need to send an email using the Request for Action – Email template to the nominated Outlook Inbox on the Request for Action Assignment

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Contacts List available under resources on the CPIT intranet page. Refer to Complaints Resolution and Oversight Template Guide for email template.

Complaints Officers should use their judgement when sending RFAs to Partners. This is because Partners are not the delegates and are unable to approve quotes or plans, update participants’ disability, approve restream requests, etc. Seek advice from a Senior Complaints Officer if unsure.

All off-system Level 2 RFAs are emailed from the redacted: s47E(d) - certain operations of agencies mailbox.

Level 3 off-system RFAs are sent from the below centralised email accounts: redacted: s47E(d) - certain operations of agencies

Note: the above inboxes are for Internal Use only.

For Level 2 Complaints ensure that a system record is maintained by creating CRM RFA and assigning to redacted: s47F - personal privacy (login: Y4O) CRM inbox as a holding bay while manual RFA is in progress.

No further action is required until the RFA is responded by the relevant business area. At this stage, the Complaints Officer can move to the next complaint. Note: Level 3 Complaints are to follow relevant team process for recording RFA.

7.4.3 RFA endorsement

All Level 2 RFAs must be endorsed by a Senior Complaints Officer/Team Leader prior to creating in CRM and sending to the relevant business area for action. Use the below steps to create RFAs for endorsement:

• Access Complaints Resolution and Oversight Template Guide document on intranet.

• Copy CRM RFA template or Manual Request for Action – Email template into body of email (this will depend whether it is an on-system or manual RFA)

• Enter required information and email it to COMPLAINTS.INTERNAL inbox for endorsement

• After the RFA is endorsed by Senior Complaints Officer/Team leader:

  1. Assign RFA (for CRM based)/send email (where manual RFA) to the relevant business area using the contacts in the Request for Action Assignment Contacts List available under resources on the CPIT intranet page.

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2. Save email as Outlook message format on to desktop; and
3. Upload saved email to Attachments within the My Requests Tile.

Note: If RFA includes staff feedback, omit staff member’s details prior to attaching email in CRM

Note: Refer to the email template listed in the Complaints Resolution and Oversight Template Guide to email off-system RFAs

7.4.4 Alert email notification to business area to advise of RFA assignment

Check the Request for Action Assignment Contacts List available under resources on the CPIT intranet page for the relevant business area to confirm whether they require an email in addition to the CRM RFA assignment. If YES, then use Email template (in Complaints Resolution and Oversight Template Guide) and email the business area regarding CRM RFA assignment template.

7.4.5 Request for Action Response

A My Requests work item cannot be closed until all Requests for Action have been closed.

For on-system RFAs the relevant business area will update the RFA work item with details of the actions undertaken/to be undertaken and change the RFA Status to Closed. The Request for Action will automatically reassign to the Complaints Officer managing the complaint.

Note: Once the RFA is updated, the business area closes the RFA section of the complaint rather than the complaint work item. Closing the complaint prematurely prevents Complaints Officers from completing necessary processes.

For manual/off-system RFA, after the response is received from the business area that the RFA was issued to, the Complaints Officer will need to update the RFA currently assigned to holding bay redacted: s47F - personal privacy (login: Y4O)]. To do that, Complaints Officers will need to reassign the RFA back to themselves from the holding bay, update it with the response received/actions undertaken by the relevant business area and change the RFA Status to Closed.

If a Complaints Officer is away on leave, their Team Leader can request another Complaints Officer to reassign the RFA to themselves and action/close the RFA on team member’s behalf. To do this select Closed from the dropdown list in Status field.

Review any information provided in the RFAs.

7.4.6 Request for Action Escalation

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Complaints Officers must complete the RFA Escalation template in Complaints Resolution and Oversight Template Guide and email it to COMPLAINTS.INTERNAL inbox for the Team Leader/Senior Complaints Officers to escalate in the following situations:

• If the response from the business area does not address the RFA adequately, or
• If the response is not received by the due date and the complaints officer has followed it up with the business area at least once via phone/email to ensure timely completion, or
• If the complaint is close to becoming overdue i.e. is at 17-18 days.

The RFA Escalation template should include information about the action/information sought and the steps undertaken/advice provided by the business area to date.

If the RFA relates to a Level 3 complaint, follow stream processes.

8. Payment Enquiries

If you have a complaint that requires action to be taken by the Payments Branch, a Payment Enquiry is required. These enquiries are created through the Payment Enquiries app.

Step by step instructions on how to create and action a Payment Enquiry are outlined in the Standard Operating Procedure - Enter Escalation Payment Enquiry in NDIS Business System.

9. Follow-up Process

Where action cannot be completed prior to complaint closure date, a follow-up interaction must be recorded BEFORE closing the complaint item. This is referred as the Follow-up Process.

Examples for when Complaints Officers can create a follow-up interaction include:

• where a participant meeting/plan review will be held outside of the 21day complaint timeframe; or
• where a business unit has committed to follow up with the complainant to confirm outcome such as quote approvals, approval of Assistive technology, etc., which are outside the 21day timeframe.

Follow-up interactions will be automatically scheduled for review within 28 calendar days from the day the interaction is created. If follow-up is required in a timeframe of less than 28 days, a shared calendar item will need to be recorded in Complaints Internal on the date it needs to be followed up.

Follow the steps listed in Complaints Resolution and Oversight Template Guide to create a Follow-up Interaction and make sure the interaction is Open. Selecting Open will place the interaction as a task to complete in the relevant CRM inbox.

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Note: Do not update the Status of the interaction to Completed if you are assigning it to CR PF CR B1 holding bay, as only an Open interaction will workflow to another team/holding bay.

The Track and Triage (T&T) team is responsible for following up all Follow-up Interactions weekly. T&T team reviews the follow-up interactions individually to ensure all actions are complete prior to closing the interactions. Where the follow-up action is not complete and the due date has passed, the T&T team will notify the Complaints Officer of the overdue interaction. The Complaints Officer is then responsible for following up with the relevant business area to ensure completion of the outstanding action. This follow up is critical to reduce the incidence of a repeat complaint about the same issue and may include additional contact with the complainant to explain the steps you are taking to follow up action.

9.1.1 If follow-up contact is required in less than 28 calendar days

Follow-up interactions will be automatically scheduled for follow-up within 28 calendar days from the day the interaction is created.

If the outstanding actions require follow-up prior to the 28 calendar days, the follow-up interaction will need to be recorded as per the previous steps and a shared calendar item will be added on the date the Complaints Officer has agreed to follow-up.

Follow the steps in Complaints Resolution and Oversight Template Guide on creating a follow-up interaction for less than 28 days. T&T team will use the Complaints Internal calendar to action these follow-up interactions.

10. Closing a Complaint Item

Prior to closing a complaint, please ensure the following is completed.

• Any correspondence or verbal communication related to the complaint is recorded in CRM. i.e. emails attached in inbound documents, discussion summaries recorded in interactions, etc.
• Ensure all RFAs have been completed and closed.
• For actions (such as Payment Enquiries) that other areas have committed to undertake which are unlikely to be completed prior to the complaint due date, create a follow-up interaction in CRM.
• A clear explanation has been provided to the complainant regarding the action taken to resolve the complaint, via their preferred communication channel. This call or email must be recorded in the interaction linked to the complaint.

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In the Outcomes tile of the complaint, update the Outcome Notes using the template available in Complaints Resolution and Oversight Template Guide. These are to be used as guidance and can be tailored as required. The Status is then changed to Closed.

Create an interaction using follow-up interaction template in Complaints Resolution and Oversight Template Guide.

Note: Depending on the channel of the complaint, Complaints Officers and Senior Complaints Officers may need to follow a clearance process. In particular when a written response is being issued to a government agency or representative.

10.1.1 For detailed information about closing a complaint in all teams within CPIT refer to the following resources:

Complaint Type	Link to closing information
Ministerial Response	Standard Operating Procedure - Finalising a Ministerial Complaint
Commonwealth Ombudsman Response	Standard Operating Procedure - Finalising a Cleared Commonwealth Ombudsman Response
AHRC Response	Standard Operating Procedure - Managing a complaint from the Australian Human Rights Commission
NDIA Commission	Managing a Complaint from the NDIS Quality and Safeguards Commission
Freedom of Information	Managing Freedom of Information Enquires Sent to CPIT
NSW Ageing and Disability Commission	Managing requests from the NSW Ageing and Disability Commission
MaSCO Service Standards	Member and Senators Contact Officer Service Standards
Participant Critical Incident	SOP 1 Initial response to a Critical Incident

SOP 2 Internal Notification of a Participant Critical Incident |

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Complaint Type	Link to closing information
	SOP 3 Undertaking follow up for a Participant Critical Incident

SOP 4 Closure and reporting of a Participant Critical Incident | | Executive Complaints Response | Executive Complaint New Starter Guide |

11. Related procedures and resources

• NDIS Act 2013
• NDIS Rules
• NDIS Our Guidelines
• Standard Operating Procedure - Allocating and Receiving a Complaint
• Request for Action Factsheet
• Complaints Resolution and Oversight Template Guide
• Managing Unreasonable Behaviour - Guideline - final.pdf (ndia.gov.au).
• De-escalation Techniques Flow Chart (pdf 57KB)
• Managing unreasonable behaviour — call handling techniques
• Practice Guide — Data Dictionary for My Customer Requests App

12. Feedback

If you have any feedback about this Standard Operating Procedure, please email it to the Business Improvement Team. In your email, remember to include the title of the product you are referring to and describe your suggestion or issue concisely.

13. Version control

Version	Amended by	Brief Description of Change	Status	Date
1.0	BC0038	Initial Version	APPROVED	2021-03-10

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Version	Amended by	Brief Description of Change	Status	Date
2.0	SGN258
JS0061	Appendix C and Appendix D added to SOP.	APPROVED

JS0061 | 2021-08-23 | | 3.0 | Y4O | Revised draft SOP | | 2022-01-06 | | 4.0 | JS0106 | Revised SOP to include all CPIT team processes. Separated templates to another document. Cleared by BM for publishing | APPROVED | 2022-03-24 | | 5.0 | GIH718 | Y4O | Amended to include information regarding repeated and unreasonable complaints | APPROVED |

Y4O | 2022-09-22 | | 6.0 | JS0106 | Update to add Fraud option to manual RFA template and emails to Fraud team and response to complainant | APPROVED |

JS0061 | 2023-01-12 | | 7.0 | NGC832 | HSP875 | Updated CPIT Management and Recording of Multi-channel Complaints. | APPROVED |

HSP875 | 2023-02-23 | | 8.0 | NGC832 | HSP875 | Formatting updated. Updated Risk Assessment process- removed outdated CPIT risk escalation matrix (timeframes removed). | APPROVED |

HSP875 | 2023-05-17 | | 9.0 | MPO0075 | Update to General considerations to include clarification between Complaints and Oversight Template Guide and Guide to Interactions in the NDIS Business System. | APPROVED |

HSP875 | 2023-08-02 | | 10.0 | NGC832 | Updated as per request from CR to include new process for ND and HAL decision explanation requests. Added in new Section 7.7 | APPROVED |

TEM907 | 2023-10-18 |

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14. Appendices

14.1 APPENDIX A – Resolving Complaints Workflow

The following page shows the workflow for resolving complaints and highlights above steps in the process map (marked in red).

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Step 4.5

Create manual RFA using relevant template RT ee

Email RFA to Complaintsinternal Step 4.5.4

Create on system RFA post endorsement

Assign AFA to CRM inbox of relevant business area

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YES ==“ “ NO

Assign RFA to Y40 CRM inbox

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Image caption: Resolving complaints process flow chart.

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14.2 APPENDIX B — Complaints Risk Escalation Matrix

The risk rating is determined by assessing a combination of the likelihood of the event recurring and the seriousness (consequence) of the event. The risk matrix below is to assist with assessing the risk of Complaints.

Step 1: The level of risk is determined by considering:

How likely is it to occur again?

What is the potential consequence if it does occur again?

Likelihood	Consequence Insignificant 1	Consequence Minor 2	Consequence Moderate 3	Consequence Major 4	Consequence Extreme 5
	Minimal impact dealt with through routine operations at an operational level	Some impact but able to be dealt with at an operational level	Impact resulting in concerns that require significant review and action to manage and ensure no ongoing concerns	Considerable impact on operations. Significant action required including escalation to leadership.	Critical failure — major incident requiring escalation to Senior Executive.
Rare 1 Unlikely to recur	Low Accept the Risk — Routine Management	Low Accept the Risk — Routine Management	Low Accept the Risk — Routine Management	Medium Awareness of risk - Routine Management	High Active Risk Management - Urgent Response and Action (Notify EL1)

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Likelihood	Consequence Insignificant 1	Consequence Minor 2	Consequence Moderate 3	Consequence Major 4	Consequence Extreme 5
	Minimal impact dealt with through routine operations at an operational level	Some impact but able to be dealt with at an operational level	Impact resulting in concerns that require significant review and action to manage and ensure no ongoing concerns	Considerable impact on operations. Significant action required including escalation to leadership.	Critical failure — major incident requiring escalation to Senior Executive.
Unlikely 2 Possibly will recur (could occur in two to five years)	Low Accept the Risk — Routine Management	Medium Awareness of risk - Routine Management	Medium Awareness of risk - Routine Management	Medium Awareness of risk - Routine Management	High Active Risk Management Urgent Response and Action (Notify EL1)
Possible 3 Probably will recur, might occur (may happen every one to two years)	Low Accept the Risk — Routine Management	Medium Awareness of risk - Routine Management	Medium Awareness of risk - Routine Management	High Active Risk Management Urgent Response and Action (Notify EL1)	High Active Risk Management Urgent Response and Action (Notify EL1)

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Likelihood	Consequence Insignificant 1	Consequence Minor 2	Consequence Moderate 3	Consequence Major 4	Consequence Extreme 5
	Minimal impact dealt with through routine operations at an operational level	Some impact but able to be dealt with at an operational level	Impact resulting in concerns that require significant review and action to manage and ensure no ongoing concerns	Considerable impact on operations. Significant action required including escalation to leadership.	Critical failure — major incident requiring escalation to Senior Executive.
Likely 4 Will probably occur in most circumstances (several times per year)	Medium Awareness of risk - Routine Management	Medium Awareness of risk - Routine Management	High Active Risk Management Urgent Response and Action (Notify EL1)	High Active Risk Management Urgent Response and Action (Notify EL1)	Extreme Urgent Risk Management - Major issue Response Escalation to EL2/SES
Almost Certain 5 Expected to occur again, either immediately or	Medium Awareness of risk - Routine Management	Medium Awareness of risk - Routine Management	High Active Risk Management Urgent Response and Action (Notify EL1)	Extreme Urgent Risk Management - Major issue Response Escalation to EL2/SES	Extreme Urgent Risk Management - Major issue Response Escalation to EL2/SES

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Likelihood	Consequence Insignificant 1	Consequence Minor 2	Consequence Moderate 3	Consequence Major 4	Consequence Extreme 5
within a short period	Minimal impact dealt with through routine operations	Some impact but able to be dealt with at an operational level	Impact resulting in concerns that require significant review and action to manage and ensure no ongoing concerns	Considerable impact on operations. Significant action required including escalation to leadership.	Critical failure — major incident requiring escalation to Senior Executive.

The Matrix allows for the calculation of risk by multiplying the likelihood score by the consequence score. Ratings are allocated using the scale below except for when the consequence is rated as Extreme. In these cases, risk is rated as a minimum of “High”.

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Step 2: If required use the escalation table below to review examples of situations/issues that would reflect the different levels of risk.

Risk Category	Low	Medium	High	Extreme
Risk to health and wellbeing a) Risk to the life of participant or another b) Permanence and continuous effect	• No risk to life of participant or another. • Failure to action the request is unlikely to result in a negative impact on a participants’ health/well-being.	• No risk to life of participant or another. • Failure to action the request is likely to/has negatively impacted the participants’ health/well-being.	• Potential risk to life of participant or another. • Failure to action the request is likely to/has resulted in an immediate risk to severe harm or permanent effect on a participants’ health/well-being.	• Failure to action the request is likely to/has resulted in loss of life.
Risk to ability to live an ordinary life • Impact on job • Impact on the day to day	• The plan is due for a scheduled review and there is no risk to employment or critical supports.	• The plan will expire or funds will be exhausted within a month so that critical supports cannot be accessed resulting in a potential risk to employment and/or a	• The plan is about to expire (within a week) or funds almost exhausted so that supports that are immediately needed will not be able to be	• The plan has expired or funds exhausted so that critical supports that are immediately needed but cannot be accessed impacting on day to day life.

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Risk Category	Low	Medium	High	Extreme
		minor impact on the individual’s day to day life.	accessed resulting in a loss of employment and/or a sizable impact on the individual’s day to day life.
Change of care arrangements	• Care arrangements unlikely to change	• Absence of supports (formal and informal) is contributing to care arrangements potentially changing in the next 6 months.	• Absence of supports (formal and informal) is contributing to Care arrangements changing, or likely to change in the next 6 weeks.	• Absence of supports (formal and informal) is contributing to an immediate risk of family (informal) or formal care breakdown.
Change of accommodation arrangements	• Accommodation arrangements unlikely to change.	• The participant’s accommodation may be at risk due to changes in accommodation arrangements or	• The participant may be at risk of experiencing homelessness due to changes in	• The participant is at immediate risk of experiencing homelessness due to changes in

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Risk Category	Low	Medium	High	Extreme
		inappropriate housing solutions within the next 6 months.	accommodation arrangements or inappropriate housing solutions within the next 4 weeks.	accommodation arrangements or inappropriate housing solutions.
Risk to Agency Reputation	• No expected escalation of the complaint.	• Risk of an escalation of the complaint or significant risk to agency reputation if escalated.	• Significant impact on public confidence or trust and/or Agency reputation. Escalation received for Ministerial or Media involvement.	• Where a failure to respond or act in the timeframe would lead to the NDIA: • Where the Minister or NDIA will be engaging with the media • Where the MO have identified specific sensitivities with extreme timeframes (egg. QTB)

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Risk Category	Low	Medium	High	Extreme
Deterioration of Key Stakeholder Relationships Jurisdiction, Ombudsman, Tribunal	• No expected escalation of the complaint.	• Where a failure to respond or act would prevent the NDIA effectively engaging with the stakeholder.	• Where a failure to respond or act in the timeframe would breach convention or agreed timeframes.	• Where a failure to respond or act in the timeframe would lead to the NDIA breaching mandated timeframes.

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