Aligned with RACGP Standards (5ᵗʰ ed), Australian Open Disclosure Framework, and relevant state/territory laws
1. Establish a Visible, Accessible Feedback Process
- Ensure patients know how to provide feedback (website, brochure, waiting room signage).
- Nominate a complaints coordinator and ensure all team members know the escalation process.
- Complies with RACGP Criterion C3.2 E and supports QI1.2 (patient feedback collection).
2. Receiving a Complaint
| Action | Standard |
|---|
| Acknowledge receipt | Within ≤3 business days |
| Thank and apologise for the patient’s experience | Immediate |
| Outline the process and timelines | In initial response |
- Apology wording: Avoid speculation or blame. State facts known at the time and commit to providing further updates when appropriate.
- Document communication clearly and respectfully.
3. Open Disclosure (When Harm or Risk of Harm Occurs)
- Trigger: Any event causing harm or a near miss with high risk of harm.
- Framework:
- Offer a sincere, factual apology (apology ≠ legal liability).
- Provide a clear explanation of what is known.
- Establish a plan for ongoing updates.
- Record in open disclosure documentation (separate to EMR).
4. Investigation & Systems-Based Review
- Gather relevant facts, records, and staff accounts.
- Analyse root cause using a just culture approach (focus on systems, not blame).
- Engage your medical indemnity insurer early if care or conduct is criticised.
- Store investigation notes outside the clinical record.
5. Resolution & Written Response
| Complaint Type | Response Time | Action |
|---|
| Simple / low risk | ≤ 30 days | Phone or written reply + apology |
| Complex / clinical / systemic | ≤ 90 days | Face-to-face or detailed letter |
- Provide a clear explanation, actions taken, and outcomes.
- Include external review options (e.g., AHPRA, HCC).
- Ensure ongoing care is not compromised; offer alternate practitioner if needed.
6. Learning, Improvement, and Audit (QI1.3)
- Use the complaint to drive clinical or administrative improvements.
- Implement changes (e.g., process update, staff training).
- Close the loop: audit post-intervention effectiveness and share findings with staff and—when appropriate—the patient.
7. Staff and Practitioner Support
- Offer debriefing and psychological support as needed.
- Apply second-victim support principles.
- Maintain fairness and non-punitive investigation tone.
8. Record-Keeping and Confidentiality
- Maintain a secure, dedicated complaints log separate from clinical notes.
- Mark EMR only with a neutral note (e.g. “feedback received – see admin record”).
- Follow the Privacy Act 1988 and APPs (Australian Privacy Principles).
9. Culturally Safe and Inclusive Complaints Handling
- Ensure complaint handling is culturally sensitive, especially for Aboriginal and Torres Strait Islander patients:
- Offer plain language communication,
- Engage an Aboriginal health liaison officer or advocate if available.
10. Escalation Tree (Internal Workflow)
textCopyEditFront-line staff → Complaints Officer → Practice Principal
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Notify indemnity insurer (if clinical issue)
11. External Complaints Pathways for Patients
| Authority | Examples / Role |
|---|
| Health Complaints Entities | e.g., Health Ombudsman QLD, HCC VIC – for care/safety issues |
| AHPRA & Medical Board | Professional conduct, performance, impairment |
| National Health Practitioner Ombudsman | Handles complaints about AHPRA processes |
| Hospitals / Services | Patient liaison or complaints department |
| Medicare / Private Insurers | Billing or administrative issues |
| Legal Pathways | Negligence, injury, or misconduct claims |
Quick Reference Checklist (Front Desk & Admin Use)
- Acknowledge complaint within 3 business days
- Offer factual apology and outline process
- Escalate to insurer if clinical issue
- Investigate thoroughly and document
- Respond with written outcome ≤ 30/90 days
- Implement and audit improvements
- Support involved staff
- Maintain secure and separate records
- Respect ATSI cultural needs
- Provide external complaint pathway info
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