Level 2 complaints - vulnerable customers and high risk complaints (CLK)(MED) 104-02040020

Complaints about staff that include statements about a staff member's behaviour not being in accordance with the APS Code of Conduct or include allegations of fraud, unauthorised access or disclosure of information may include:

• allegations of a breach of the APS Code of Conduct, including threats of retribution, discrimination or other serious staff misconduct
• allegations of staff accessing or disclosing information without authority or committing fraud

Level 1 staff immediately escalate these complaints to the Level 2 team for management per escalation reason 4 - Potential serious breach of APS Code of Conduct or allegations of fraud, unauthorised access or disclosure of information.

See Complaints and feedback index.

Complaints about whistle-blowers are managed in accordance with principles contained in Australian Standards AS 8004-2003.

Resources has a link to the agency's Code of Conduct manual is included on the page.

Assess the feedback details to identify the person or business area responsible for the assessment of the issues. If the complaint is an allegation of:

• APS Code of Conduct breach, go to Step 3
• fraud, unauthorised access or disclosure of information, go to Step 4

If the complaint contains allegations of an APS Code of Conduct breach:

• notify the Complaints Officer's Manager immediately
• ask the customer to provide any evidence they have to support the allegations

Level 2 Managers:

• consult with or notify Conduct and Reviews team by email and the staff member's EL2. Resources has a link to the Workplace Relations Branch contact details
• forward the complaint details in an email to the Conduct Standards team in order to protect the staff member's privacy
• refer to the Level 2 Manager if further assistance or advice is required to manage the feedback
• coordinate and manage the action and responses required if there are multiple business areas involved in the follow up action

The Conduct Standards team require verbatim details of the complaint to assess whether action will be taken.

Go to Step 5.

If the complaint contains allegations of staff fraud, unauthorised access or disclosure of information:

• only notify the Employee Fraud team. For contact details, see Internal Fraud team
• forward the full details of the complaint, in the customer's own words, in a separate email from the appropriate Level 2 team positional mailbox
• refer to the Complaints Officer's Manager if further assistance or advice is required to manage the feedback
• coordinate and manage the action and responses required if there are multiple business areas involved in the follow up action

Record the complaint in the Customer Feedback Tool, including responses from other business areas assisting with the complaint.

To protect the staff member's privacy, do not record the details of the allegations on the customer's record.

See Complaints and feedback index.

The preliminary assessment by the Conduct Standards or Internal Fraud teams:

• decide whether any action will be taken about the allegation
• notify the Level 2 team if any action will be taken

If the Complaints Officer is advised no action will be taken by Conduct Standards or Internal Fraud:

• refer the complaint to the staff member's manager, normal staff behaviour actions apply and this will be managed by the staff member's manager
• manage the complaint per Complaints and feedback index
• update the escalation reason in the Customer Feedback Tool
• update the Customer Feedback Tool entry with the advice from the Complaints Officer's Manager or from the responsible business team. Do not include details about the assessment, it should simply be an acknowledgement and confirmation that no action will be taken

If the Complaint Officer is advised by the Conduct Standards or Internal Fraud team advises that action will be taken:

• update the Customer Feedback Tool entry with the advice from the business team. Do not include details, just acknowledge that action will be taken
• finalise the Customer Feedback Tool entry

The staff member's Manager updates the service request, see Complaints and feedback index.

The response to the customer is dependent on the information received from the responsible business team.

If the Complaint Officer is advised by the Conduct Standards or Internal Fraud team advises that action will be taken:

• advise the customer that action is being taken and that they will not be informed of the outcome of any action
• finalise the complaint

If the Complaints Officer is advised no action will be taken by Conduct Standards or Internal Fraud:

• offer an apology to the customer for the service experience
• advise the customer:
• their feedback will be referred to the staff member's manager for follow up and discussion
• they will not receive further contact unless the manager specifically needs more information to investigate the complaint

Return to Level 2 complaints (CLK)(MED) to continue managing the complaint.

For information about recording complaints, compliments and suggestions from customers with a CALD status, see Step 4 in Table 5 of Level 1 – Manage complaint and feedback.

Systemic Issues or complaint trends identified

If a systemic issue impacting on CALD customers is identified or advice is required during the management of a complaint, notify Multicultural Services. Resources has a link to the Multicultural Services homepage.

For information about recording complaints, compliments and suggestions from customers with an Indigenous status, see Complaints and feedback index - ABSTUDY.

Systemic Issues or complaint trends identified

If a systemic issue impacting Indigenous customers is identified or advice is required during the management of a complaint, notify the Indigenous and Remote Servicing Branch. For contact details, see Indigenous and Remote Servicing Branch.

When a customer with a Managed Service Plan (MSP) contacts the agency, the staff member taking the call:

• determines the customer's MSP conditions in the Customer Incident Management System (CIMS) in the customer's record (Centrelink) or as recorded in CDMS (Medicare)
• follows the MSP arrangements prior to assisting the customer with their complaint or feedback
• contacts the customer's One Main Contact (OMC) (if the customer has one) to discuss and determine the correct management of the customer and complaint issues. This may result in the OMC managing the customer's complaint and feedback issues and recording the complaint in the Customer Feedback Tool
• follows the MSP instructions prior to assisting the customer with their complaint or feedback if there is no OMC, documenting the customer's record with details of the contact
• records the complaint in the Customer Feedback Tool, if there is no OMC

If the customer is making a complaint or providing feedback, go to Step 2

Managed Service Plans (MSP) specify the way a customer can communicate with the agency. They do not restrict how the agency contacts the customer. The agency has a range of service delivery needs where direct contact with the customer is necessary. Responding to customer complaints and feedback is one of these.

If a customer with an MSP is making a complaint about their One Main Contact (OMC), Level 1 staff warm transfer the customer to Level 2 in accordance with the agency's Customer Complaint and Feedback Policy. This does not preclude the Complaints Officer from liaising with the OMC.

The Complaints Officer must consult with the customer's OMC if customer contact is required in relation to any complaint from a customer with an MSP. This collaborative approach:

• ensures the agency considers the safety of staff as well as managing the customers service delivery needs
• provides confirmation direct contact is appropriate given the customer's behaviours and circumstances
• provides visibility to the OMC of current service issues, noting the OMC should be aware of these as per their roles and responsibilities
• provides a coordinated and timely response to the customer, reducing the likelihood of repeat contacts and breaches of the customer's MSP

If the customer has a Workplace Order in place:

• consideration of this Order is paramount in any contact with the customer
• legal advice must be sought from the via Customer Aggression Prevention Security so contact can be arranged. Resources has a link

Internally escalated complaint

Personalised Services (PS) Officers can escalate complaints to the Level 2 team when the customer's complaint meets an escalation reason.

When a PS Officer determines a complaint meets an escalation reasons, the PS Officer:

• contacts a Complaints Officer on the warm transfer line
• advises the Complaints Officer of the customer issue
• identifies any particular requirements to be considered

Personalised Services customers are not warm transferred to a Level 2 Officer.

The PS Officer:

• advises the customer:
• the complaint will be investigated and actioned by a Complaints Officer
• the PS Officer will remain the customer's single point of contact of the complaint outcome
• creates the Customer Feedback Tool entry
• advises the Complaints Officer of the complaint identification number
• contacts the customer to advise the complaint outcome

The Complaints Officer:

• locates and allocates the entry in the Customer Feedback Tool on receipt of the identification number from the PS Officer
• investigates the complaint and completes any action required
• updates the Customer Feedback Tool entry in real time as investigation and actions occur
• frequently or as agreed provides the PS Officer with updates on the management of the complaint. If any additional information is required to assist in the management of the complaint the PS Officer will action all customer contact requirements
• advises the PS Officer of the outcome of the complaint - the PS Officer contacts the customer to advise the complaint outcome
• finalises the complaint once the PS Officer has advised the customer of the outcome

Complaint received from external source

When customer contact is required during the management of a complaint for a PS customer received from an external source. For example, Ministerial and Ombudsman complaints:

• liaise with the identified PS Officer to determine the most appropriate person to contact the customer
• record a Customer Feedback Tool entry
• prepares any written response required

The Australian Government Guidelines on the Recognition of Sex and Gender apply to all Australian Government departments and agencies that maintain personal records (including employee records) and collect gender information.

The guidelines outline a consistent standard of evidence when gender is being verified or changed. The guidelines also define the gender classifications of male (m), female (f) and non-binary (x). A person of non-binary gender does not exclusively identify as either male or female.

Currently not all Services Australia's personal records systems allow staff to update a customer's records to reflect their gender as non-binary, or indeterminate gender (X). There will be an update to all systems to include a non-binary/indeterminate gender (X) option.

Level 2 Complaints Officers:

• receive complaints from customers who raise concerns about gender issues via warm transfer from Level 1 staff
• confirm the reason for the complaint has been correctly recorded by Level 1, see Complaints and feedback index
• see Updating gender details on customer records for more information about assisting transgender, intersex and non-binary customers
• help the customer to update their gender details in Centrelink, until the option is available across all service brands
• offer to help the customer's submit updates to their records for Medicare and/or Child Support. For example, remove their title, and change their name if applicable
• offer the customer a referral to a social worker if appropriate

The Restricted Access is available for customers seeking additional protection of personal information held by Services Australia. It is a computer based security system which denies access to the customer's computer record for the majority of staff. Only a limited number of staff in the customer's home service centre and the agency's Canberra site can access the record. The purpose of Restricted Access is to protect the customer's location details.

Restricted Access is available to customers who have genuine fears for their safety, or where there is a risk that a staff member could endanger the customer by accessing the customer's computer record. Restricted Access should only be used in exceptional circumstances.

Internally escalated complaints

Immediately transfer the call if the customer is not calling to provide feedback, use the procedures for Restricted Access customers.

As the feedback will be treated anonymously, certain restrictions apply.

Level 2 Complaints Officers:

• advise the customer the Complaints Officer will:
• not be able to access the customer's record or investigate the feedback if provided
• not be able to investigate their customer record to confirm who the feedback relates to
• forward their email to the relevant staff member's Manager if they can provide details of the person the feedback relates to. The customer's details will not be recorded and will not be provided to the Manager (who will therefore treat the complaint as anonymous)
• pass on the feedback to the appropriate team if it is about a payment or service issue. The customer will not receive a response
• pass particular staff member feedback to the customer's responsible officer for follow up if the customer specifically requests a response to their feedback. The responsible officer will also document the feedback and as otherwise required on the customer's record
• offer to transfer the call to the customer's responsible officer

Complaints received from external source

Complaints received from external sources, for example Ministerial and Ombudsman referrals, require Complaints Officers to:

• contact the National Restricted Access Team and request temporary access to the customers record to enable the complaint to be investigated and managed
• liaise with the Restricted Access Manager to determine the most appropriate person to contact the customer if customer contact is required
• record a Customer Feedback Tool entry
• prepare any written response required

Return to Level 2 complaints (CLK)(MED) to continue managing the complaint.

On 1 January 2015 the Department of Human Services (previous name of Services Australia) introduced changes to the claim and assessment process for Disability Support Pension (DSP). DSP claimants are no longer required to provide a Medical Report (SA012), instead they must provide existing medical evidence, such as clinical notes, test results and specialist reports to support their claim. See Eligibility for Disability Support Pension (DSP).

Claimants may also be required to attend a Disability Medical Assessment (DMA) with a Government-contracted doctor (GCD) as part of their claim process. See Disability Medical Assessment (DMA) referrals.

To manage the complaint:

• determine the issues that will be investigated based on the information provided by the customer
• ask appropriate and targeted questions to establish whether the complaint is about the rules, the decision, the claim process, the assessment process or the conduct of the assessor or GCD. This will ensure correct recording and attribution of the complaints and assist to determine which team is best placed to help with the complaint investigation and response
• ask the customer if they have been asked to provide more medical information if appropriate. If it has been less than 21 days since the customer's Job Capacity Assessment (JCA) appointment and the JCA screens show that the assessment is 'on hold' this means the agency is waiting on more medical information from the customer

To record the complaint, see Complaints and feedback index.

Return to Level 2 complaints (CLK)(MED) to continue managing the complaint.

Farm Household Allowance (FHA) complaints and feedback received at the first point of contact are escalated via warm transfer to Level 2 staff. Customers in receipt of FHA can be classified as highly vulnerable.

Level 2 Complaints Officers:

• determine the issues that will be investigated
• ask appropriate and targeted questions to establish what the complaint is about. For example, an FHA ICT issue, the rules, the decision, the claim process, the assessment process. This ensures correct attribution of the complaint and assists to determine which team is best placed to help with the complaint investigation and response
• complete the FHA SCIRO referral form for all escalated FHA complaints. This will determine if the complaint is an ICT, processing or policy issue
• offer support to any vulnerable customers such as social work support via warm transfer to the Telephone Access Service (TAS) social work phone line or via a call back request to be actioned in Customer First

The Rural and Complex Team Smart Centre ICT referral officer (SCIRO):

• monitors the mailbox in real time and will determine the team to refer to
• logs the issue with ICT via online web form or refers to processing team or Policy area for advice
• escalates the job if the issue is urgent
• updates the FHA Spreadsheet
• liaises with the Complaints Officer until the matter is finalised
• documents the customer's record with the Service Delivery (SD) job number
• monitors the record in Service Manager for 48 hours. If the issue is not resolved in this timeframe the SCIRO escalates to an ICT EL1
• records any updates on the customer's record as they occur
• emails the Level 2 Officer back within 48 hours with an update

The FHA team provides the Complaints Officer with a response.

Return to Level 2 complaints (CLK)(MED) to continue managing the complaint.