The Department has accepted all but one of the 11 recommendations resulting from this assessment and the Department's comments have been incorporated into it. However, I remain concerned that, as the second job placement contract comes to an end, a number of monitoring and audit reports reviewed in the course of the investigation have revealed shortcomings in the arrangements for handling complaints by providers.
DEWR’s handling of complaints about the Job Network
In November 2002, the JQIS outcome classifications were expanded to record the actual outcome of the complaint, not just the level of the complainant. When a complaint concerns a provider and that country has approached and helped, but is unable to meet the complainant's expectations, when these are outside the scope of the contract;.
Ombudsman access to information
B ACKGROUND TO THE I NVESTIGATION
I made a number of recommendations for improving the department's complaint handling procedures and practices, and. I also foreshadowed my intention to rethink the Job Network's complaint handling at an early stage.
S COPE OF I NVESTIGATION
The Job Network comprises provider organizations contracted by the responsible agency (then the Department of Employment, Workplace Relations and Small Business - DEWRSB)1 to provide employment services in accordance with a Code of Conduct which included, among other things, a effective. This, of course, includes the provision of employment services by third party providers through the Job Network.
M ETHODOLOGY
I expect that the proposed amendments to the Ombudsman Act 1976 will give me access to much more detailed information about the handling of complaints within the JNMs themselves in future. Review of JQIS records, DEWR complaints database, numerous complaint records relating to sites in Victoria and Western Australia; and.
P ERFORMANCE AGAINST 2001 RECOMMENDATIONS
- Complaints handling processes within JNMs
- Handling of complaints about the Job Network within DEWR
Monitoring visits include a component addressing complaint handling, which requires monitoring staff to conduct a review of JNM's complaints processes and complaint records made since the last monitoring visit. WA monitoring visit reports generally provided some detail about the operation of the JNM complaints process and the quality of service provided. These differences may reflect differences in the understanding and experience of the undertaking officers.
Therefore, the accuracy of CSL complaint records can be a useful indicator of the accuracy of complaint records made directly to JNM. Referral of the complainant to the JNM for resolution should only occur when it is clear that the complainant is simply asking. This may include the provider explaining the nature of the complaint or the complainant explaining the provider's position on the matter.
JQIS addresses many of the shortcomings of the previous system and is gradually revised and improved. Reasoning or otherwise of complaints to DEWR can therefore be a key indicator of the effectiveness of complaint handling in JNMs.
R ECOMMENDATIONS ARISING FROM 2002 REVIEW
- Complaint handling processes in JNMs
- DEWR’s handling of complaints about the Job Network
- Ombudsman access to information
That DEWR consider options to encourage greater awareness among JNMs of the value of complaints mechanisms as a means of providing important information on ways to improve the overall business. It also questions the appropriateness of DEWR's referral of complainants to a JNM when there may be doubts about the effectiveness of the JNM's complaint handling arrangements. Improving the review of the monthly sample of complaints by the head office, focusing on best practices for CSOs, may also be appropriate.
This DEWR reminds CSOs of the need to maintain an independent role in investigating complaints and to avoid becoming their own advocates. However, classifications of complaint outcomes are primarily based on the complainant's perspective and primarily reflect the complainant's level of satisfaction with the complaint outcome. That DEWR reviews the score classifications for JQIS with the goal of ensuring that they accurately reflect an objective assessment of the outcome of the complaint, rather than focusing solely on the complainant's level of satisfaction with the response to the complaint.
The monitoring process
Conduct of monitoring visits in Victoria
The latter 3 reports were compared with the complaints handling findings of the quality audit reports on the same sites. The checking of the complaint register also appeared rather cursory and was not mentioned at all in 2 of the five reports. However, the qualitative aspects of comments were limited and did not address issues of the comprehensibility or accessibility of the information displayed or provided.
Two of the reports contained no qualitative assessment of the procedures outlined, while the third site report noted that "the complaints register was viewed and all complaints appeared to be adequately dealt with". In relation to the third site report referred to in the previous paragraph, the quality audit carried out less than a year later found "(the site's) complaints procedures are clearly inadequate" and recommended a review of the complaints system and training given to staff. In relation to the second of the three sites, the monitoring report provided minimal information about the complaints process –. complaints) resolved internally – register at the counter...”.
Conduct of monitoring visits in Western Australia
The main issues addressed in monitoring are the provider's understanding of the need for a good complaints system, the availability of. The findings of the control visits to the last 6 sites were compared with the findings of the quality audit at the same sites. All reports mentioned viewing a complaints register or file, but only one gave a qualitative opinion on the registration.
A report noted that a copy of the site's complaints process had been provided to DEWR previously, but there was no comment on any checks during the monitoring visit to ensure that the process was actually working effectively. The findings of the monitoring visits, together with a subsequent risk assessment, identified these sites as sites where. As a consequence, a qualitative audit of three of the provider's sites was undertaken during the first half of 2002, with particular attention to defects in the complaints handling arrangements identified in the monitoring visits.
The Quality Audit process
Examples are provided of appropriate recommendations for inclusion in a report where the audit has identified a need for improvement in compliance with any aspect of the Code of Conduct.
Conduct of QAs in Victoria
A number of the reports in 2001-2002 were not completed within the 6 week time frame set by the QA guidelines, although according to senior staff the timing of reports has improved in recent months as report writers gain more experience . However, a monitoring report carried out a year earlier at one of the four sites audited contained only one comment about the complaints process on site: "no problems". B17 Monitoring visits were carried out at all three sites that were audited during the year prior to the audit.
None of the reports of these monitoring visits indicated any cause for concern regarding the functioning of the complaints processes. For example, in the case of sites where the audit found that the complaints process was inadequate and staff were not clear about the definition of a complaint, the recommendation was to “…review their internal complaints system and provide training to their staff on complaints handling and resolution, including what constitutes a complaint, and the Code of Conduct". The expected results can be discussed in a debriefing with the provider after the audit, but ideally they should be clarified in writing to ensure that an effective evaluation of the implementation of the recommendation can be undertaken.
Conduct of QAs in Western Australia
The reports were well structured and well written, with useful comparisons, where appropriate, of findings at different sites operated by the same providers. This was particularly useful for checking shared understandings of key issues and processes and how they worked in practice. Where significant recommendations were made, a review process to monitor implementation was envisaged in the Department's letter to JNM.
Due attention is paid to follow-up with providers through briefings to ensure recommendations are understood and visits to ensure recommendations are implemented.
COMPLAINTS HANDLING ARRANGEMENTS
Overview of the DEWR Customer Complaints Service
In the previous guidelines, there was a strong focus on appeals procedures, while the revised guidelines address issues related to the context in which civil society organizations operate and how DEWR. CSL complaints are reviewed monthly by the central office: a random sample of 10% of complaints. The review focuses primarily on the nature and seriousness of the complaints received, on which a report is prepared for the head of the ministry.
If a problem is identified in complaint handling or reporting during the review, the responsible CSO will be contacted. Significant complaints handling concerns in a state will also be escalated to the state's customer service manager.
Operation of the CSL in Victoria
In many records, it was not clear that the complainant had received a call from CSL to clarify that the action the site had agreed to take on a complaint had actually been taken; or that the complainant understood that a complaint had been fully considered and what the outcome was. For example, in 13 of the 28 complaints received by CSL about a site, the complaint was not followed up on. In many of these cases, the CSO appears to have been satisfied with a verbal assurance from the site that they would fix the problem and had no further contact with the complainant.
For example, in relation to one premises, 11 of the 16 complaints received referred to the attitude of a specific member of staff at the premises, but there is no indication that action was taken to bring the frequency of such complaints to the attention of the premises management not to establish. . For example, if a complainant has had a complaint investigated, but the complainant remains dissatisfied, despite the CSO's finding that the complaint was not. The assessment appears to be based on whether the complainant's expectations were met, regardless of whether those expectations were reasonable.
Operation of the CSL in Western Australia
