Complaints handling in aged care is now a key area of interest for the Aged Care Quality and Safety Commission (Commission).

The Commission recently released a webinar video to explain what aged care providers should do to meet expectations about the handling of complaints. At the same time, several providers have reported to ACE that the Commission’s performance reviews have been particularly focused on complaints-handling.

Today we’ve summarised some of the key points in the Commission’s webinar to bring you four ways that aged care providers can improve their complaints-handling processes to benefit consumers and pass a quality assessment.

Overview

When it comes to complaints-handling, the Commission wants to see aged care providers:

• present good posture
• maintain robust internal processes
• engage in open disclosure
• protect privacy.

Present Good Posture

According to Michelle Bampton, Executive Director of the Commission’s Intake and Complaints Resolution Group, the Commission looks at “provider’s posture” when determining the quality of a provider’s complaints-handling policies and processes.

Provider posture is “the demonstrated willingness of the provider to engage in the process, to listen to the complainant, to own where things have gone wrong, to genuinely engage in service improvement where that’s what’s required.”

There are many practical ways to present good posture, for example: listening to and recording complaints, providing complainants with a clear point of contact with whom they can talk throughout the process, making changes in response to complaints and then communicating this to complainants.

At its core, however, good posture isn’t so much a thing you do as it is a natural outcome of your workplace culture. If your workplace culture views complaints as a welcome opportunity to improve care and services, then “good posture” will follow.

Maintain Robust Internal Processes

Bampton says that the Commission also looks for “good robust internal complaints management processes”. This means “the right processes, people, skills and posture to enable complaints to be resolved properly at the local level.”

In practice, a robust complaints-handling process should:

• be properly resourced
• be easily accessible by potential complainants, including those who may have difficulty communicating
• allocate and train appropriate staff
• follow the principles of open disclosure
• foster continuous improvement.

For more information, refer to the Better Practice Guide to Complaints Handling in Aged Care Services.

Although not expressly covered in the Commission’s webinar, a complaint may alert you to the occurrence or suspected occurrence of a reportable incident under the Serious Incident Response Scheme (SIRS). Such complaints will have to be reported to the Commission in accordance with the requirements of the SIRs, including specified timelines.

Engage in Open Disclosure

According to Bampton, the Commission wants to see providers engage with the process of open disclosure. Open disclosure is “really about how providers communicate when things go wrong, whether they’re listening to the complainant, understanding what’s happened, apologise if that’s appropriate, and explain the steps taken to prevent it happening again”.

Standard 6 (Complaints Handling) and Standard 8 (Organisational Governance) of the Aged Care Quality Standards expressly require aged care providers to practise Open Disclosure when managing complaints. The Commission’s Open Disclosure: Framework and Guidance sets out this five-step process for practising Open Disclosure:

1. Identify when things go wrong: there are many ways to identify incidents, including internal complaints processes, incident reports, complaints and external assessments.
2. Address immediate needs and provide support: support includes practical and emotional support. This may involve providing clinical care within the service, bringing in health professionals from outside the service, providing translation services and hearing support, and contacting family and carers.
3. Acknowledge and apologise or express regret: according to the Commission, acknowledgements and apologies are not about blame and should be made even if the issue was “no one’s fault”. The Commission advises providers to offer, as early as possible, “a sincere and unprompted apology or expression of regret for harm or grievance caused. An apology or expression of regret should include the words ‘I am sorry’ or ‘we are sorry’”.
4. Find out and explain what happened: this is not just about collecting factual information – it’s also about giving the consumer a chance to tell their story.
5. Learn from the experience and make improvements: this stage involves analysing the information gathered during the Open Disclosure process, using it to improve services and communicating these improvements to consumers and their representatives.

Protect Privacy

The Commission wants to see providers maintaining confidentiality and protecting the privacy of individuals. However, this does not mean removing all names from documents.

During the webinar’s Question/Answer component, Bampton was asked if providers should redact names from complaints records. She answered, “We would be looking for you to redact the names of other residents that are not material to the complaint process – so definitely [redact the] names of other people.” But, she added, the name of any member of staff who may have committed misconduct should not be redacted. This was because the Commission now has an obligation to investigate individuals who may have breached the Aged Care Code of Conduct – and they want to be informed of who these individuals are.

Conclusion

Overall, the message of the Commission’s webinar was that there were “no sides”. It was not a case of provider versus complaint or versus the Commission, rather it was about working together to improve quality of care and services.

As Bampton put it, “The Commission is not looking to punish providers. What we’re looking for is a commitment to resolving the issues, to putting in place improvements if they’re required so that any issues are remediated and not repeated."

In a nutshell the focus should be on valuing complaints and the opportunities that they provide.