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Anika, you asked the wrong question

The Honorable Anika Wells, Minister for Aged Care, commissioned an Independent Capability Review of the Aged Care Quality and Safety Commission. Authored by David Tune AO PSM, the review was tasked with recommending how the Commission’s capability could be improved to better support its regulation of the aged care sector. The report uncovers an alarming array of statistics and delivers urgent recommendations, particularly emphasizing a crucial need for the Commission to rectify significant shortcomings in its complaints process. While we concur with the report's diagnosis, we disagree with the proposed treatment. We believe the fundamental premise of the report is misguided. Our combined efforts should address the root cause of the multitude of complaints, instead of focusing primarily on enhancing the Commission's ability to manage them.

The commission received over 92,000 calls, emails and web form submissions between July 2022 and the end of February 2023. These are astronomical numbers. Not surprisingly the rate of complaints resolved within 60 days has been steadily declining (75% in 2019-20, 67.6% in 2020-21, 67.3% in 2021-22). Given this, the report suggests:
The complaints system must be urgently reviewed to ensure that complaints are triaged appropriately, that complainants have assurance that concerns are being followed up, and the wider community gain trust that matters of concern to older Australians and their families are getting priority attention.
Among other urgent actions, the report specifically recommends this:
5.7 The Aged Care Complaints Commissioner to deliver an enhanced complaints management system which ensures timely responses, is transparent and accountable, integrates information, and promotes open disclosure and supports the sector to use complaints to inform continuous improvement.
The Independent Capability Review of the Commission was undertaken with the express purpose of offering recommendations to enhance the Commission's ability to effectively regulate the aged care sector. However, this objective seems somewhat narrow in scope, particularly when considering the issue of feedback and complaints. If the problem is framed as, "We are inundated with a multitude of complaints. How can the Commission better manage them?" it naturally leads to solutions centered on expanding the Commission's capacity to handle these complaints. Yet, this approach does not adequately address the root cause of the problem, sidestepping the pressing need for preventative measures that might reduce the volume of complaints in the first place.

We concur with the diagnosis, but not the treatment! Isn't it time we get to the heart of the matter? The proverbial wisdom, "An ounce of prevention is worth a pound of cure," comes to mind. From our years of industry experience and, quite simply, common sense, it's clear that a significant number of complaints reaching the Commission could have been intercepted and resolved much earlier. If providers are able to identify and address issues promptly, they are less likely to evolve into bigger problems.

Although all aged care providers are mandated to have a feedback and complaints system, the "system" for many consists of paper forms placed on a counter next to a box. This box is checked intermittently, yet might contain vital feedback that could prevent further issues. This feedback is stored in a filing cabinet, is sometimes entered into an Excel spreadsheet, or then occasionally placed in a risk management register.

Such a system falls short in addressing issues in a timely or efficient manner. It was these very insights that inspired the creation of Tell Touch four years ago.

We believe that a department-level complaints process should still exist, but it should come into play when complaints aren't satisfactorily resolved by the provider. Providers should be encouraged, supported, or even mandated to have better feedback and complaints systems.

This is how it works with banks. ASIC Regulatory Guide 271 lays out stringent guidelines for internal dispute resolution (IDR) procedures in response to consumer complaints. The Australian Financial Complaints Authority only investigates issues once a consumer has gone through the IDR process without reaching a satisfactory resolution.

An effective IDR system enables early resolution of issues, creating a win for everyone. This prevents others from encountering the same issues; consumers, families, staff, and providers become happier; the overall number of complaints diminishes; staff and management can dedicate less time to managing larger problems, leading to improved care; word-of-mouth promotion reduces marketing expenditures, and providers generally operate with greater efficiency. Everyone is a winner!

So how does the government accomplish this? While we recognize our vested interest, we feel that funds directed towards establishing better feedback and complaint management at the provider level would be more beneficial than simply beefing up a Commission-led complaints system. It was not until a government grant was in place for digital care management systems that such systems truly took off - to the betterment of care and efficiency in the industry. Now, it's time for the government to do the same with digital feedback and complaints systems.





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