This page describes supplementary information for Complaints Officers in Centrelink and Medicare managing Level 2 complaints that are high risk or from vulnerable customers.
Investigate high risk complaints and complaints from vulnerable customers
The information provided in this procedure is supplementary to the complaints management processes in Level 2 complaints (CLK)(MED). Use the drop-down menu below for extra instructions for managing high risk complaints or complaints from vulnerable customers before returning to Level 2 complaints (CLK)(MED).
All staff
A vulnerable customer
Investigating complaints
This table describes the process Complaints Officers use to investigate complaints from vulnerable customers.
A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to disadvantage. Complaints are prioritised based on the customer's circumstances. A high priority issue is when the customer is at risk or vulnerable or the impact on the customer is significant.
If the complaint does not meet an escalation reason, the complaint is managed at the first point of contact. High priority complaints are managed with urgency or as immediately as possible.
Make the relevant service offer to a complainant if they are identified as vulnerable. Use indicators of potential vulnerability to assess if it is appropriate to consult with or refer the customer to specialised business areas, including Social work services.
If a systemic issue or complaint trend is identified, go to Step 5
2
Incarcerated customers
Incarceration can make it difficult for customers to contact Services Australia. These customers will sometimes use nominees or representatives to provide feedback.
When managing complaints from incarcerated customers, contact the appropriate service officer in Face to Face Incarcerated Customer Servicing team for assistance and guidance to contact the customer and respond to the issue. Refer to the Incarcerated customer directory on the Resources page for additional information.
If a systemic issue or complaint trend is identified, go to Step 5
4
Additional referrals for vulnerable customers
While managing the complaint consider any other possible offers of support that can be provided to the customer. Resources has a link to the Payment and Service Finder.
consult the Complaints Officer's Manager for consideration of referral to a Forensic Psychologist where all available services and support have been offered
Medicare staff
If a customer is identified as being vulnerable consult with Team Leader or Program Support Manager for assistance in referral to a social worker or Personalised Services
If a systemic issue or complaint trend is identified, go to Step 5
5
Systemic issues or complaint trends identified
If a systemic issue impacting on a vulnerable customer is identified during the management of a complaint, the Complaints Officer advises the Complaints Officer's Manager and reports the systemic issue to the Systemic Issues Resolution Group (SIRG) representative. See Table 2 on the Process page of Level 2 complaints.
Allegation of potential breach of APS Code of Conduct - staff fraud and misconduct
Investigating and responding to complaints
This table provides supplementary information for Complaints Officers when investigating and responding to complaints received about a potential breach of the APS Code of Conduct due to staff fraud or misconduct.
Potential breach of APS Code of Conduct and allegations of staff fraud or misconduct
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.
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.
2
Identify complaint issue
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:
fraud, unauthorised access or disclosure of information, go to Step 4
3
Allegations of APS Code of Conduct breach
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.
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
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.
Indigenous customers
Investigating complaints
This table describes the process Complaints Officers use to investigate complaints from indigenous customers.
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.
Managed Service Plan (MSP) customers
Investigating complaints
This table describes the process Complaints Officers use to investigate complaints from customers with a Managed Service Plan (MSP).
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
If the customer is making a complaint or providing feedback, go to Step 2
2
Complaint received from customer with an MSP
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
Personalised Services customers
Investigating complaints
This table describes the process Complaints Officers use to investigate a complaint from a Personalised Services customer.
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 reason, 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
Transgender, intersex and non-binary
Investigating and responding to complaints
This table provides supplementary information for Complaints Officers when investigating and responding to transgender, intersex or non-binary complaints.
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.
Level 2 Complaints Officers:
receive complaints from customers who raise concerns about gender issues via warm transfer from Level 1 staff
This table provides supplementary information for Complaints Officers when investigating and responding to complaints received via an escalated appeals complaint.
Escalated complaints and feedback received by the Level 2 team about appeals, reviews or Authorised Review Officers are referred and allocated to the Appeals Branch via the Customer Feedback Tool.
The Appeals Branch are responsible for the start to finish management of this feedback.
Level 2 staff identify and notify Appeals and Reviews Coordination (in the Appeals Branch) of any other identified information of importance or priority during the referral process.
Appeals and Reviews Coordination is responsible for managing the feedback referred to the Appeals Branch.
Appeals and Reviews Coordination may contact the Level 2 team for advice and assistance during the management of customer feedback.
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
Disability Support Pension claiming process or Assessment Services
Investigating and responding to complaints
This table provides supplementary information for Complaints Officers when investigating and responding to complaints received via Disability Support Pension claiming process or Assessment Services.
Disability Support Pension claiming process or Assessment Services
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
This table provides supplementary information for Complaints Officers when investigating and responding to complaints received from Farm Household Allowance customers.
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.
Health fraud, compliance and inappropriate practice
Investigating and responding to complaints
This table provides supplementary information for Complaints Officers when investigating and responding to complaints received about health fraud, compliance and inappropriate practice.
the audit process, received from Health Professionals, go to Step 3
alleged inappropriate practice by Health Professionals, go to Step 4
2
INVEST message and CMBO flag
The Debt, Appeals and Health Compliance Division (DAHCD) undertakes a diverse range of compliance activities to protect the integrity of its service delivery and government outlays. For members of the public these activities include an INVEST message placed on the customer's Medicare Card or a CMBO flag placed on the customer's PIN.
Complaints officers need to complete the Medicare Payment Integrity report form available on the Customer complaints and feedback management page under 'I want to' Complete a Medicare Payment Integrity Report and send to the team responsible. Resources has a link to the Customer complaints and feedback management page.
Complaints from Health Professionals about the audit process
When a Health Professional lodges a complaint regarding an audit decision or recovery amount, the staff member should confirm with the Health Professional if they have received written notification from Debt, Appeals and Health Compliance Division (DAHCD) advising details of the offer of a Review of Decision.
In most instances, the Health Professional will be given the option to request a Review of Decision if they disagree with the audit findings. This will be conducted by an independent officer who will review the relevant services identified in the audit and notify the Health Professional in writing of the outcome.
The health professional will be notified by phone and letter before the audit begins and will be provided with the name and contact phone number of the Compliance Officer assigned to the audit case.
Alleged inappropriate practice by a Health Professional
Customers can report alleged fraud abuse or inappropriate practice by a health professional such as:
charges for services other than those provided
instances of excessive servicing or diagnostic ordering
failure to provide copies of billing documents
inappropriate use of prescription drugs
The Complaints Officer:
records the feedback as a General Enquiry in the Customer Feedback Tool and sends the details as an FYI email to the Fraud Tip-off team
advises the customer the report will be forwarded to the relevant business team for investigation however the customer will not be contacted with the outcome of the investigation
The customer has the right to remain anonymous when reporting instances of alleged fraudulent behaviour and in this instance the complaints officer should also forward the report to the Fraud Tip-off Team.
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