Complaints handling policy, Torvale Family Medical

Complaints handling policy template for a medical centre

A complaints handling policy has to make complaining easy, set times the practice will meet, and tell patients where they can go if the answer does not satisfy them. This four page Australian policy for a Victorian general practice does that with five channels, a six step timeframes table starting with acknowledgement within 2 business days, seven handling steps and a table of three outside bodies.

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Torvale Family Medical
3 April 2028

Complaints handling policy

How patients and carers raise a concern, and how the practice responds and learns from it.

Prepared by
Practice Manager
Date
3 April 2028
Complaints handling policy, Torvale Family MedicalPage 2 of 4
Complaints handling policy, Torvale Family MedicalPage 3 of 4
Complaints handling policy, Torvale Family MedicalPage 4 of 4
1
Purpose and scope
Torvale Family Medical is a general practice in regional Victoria with nine GPs, five practice nurses and about 11,000 active patients. Complaints tell the practice where care or service fell short, and handling them well is part of good care. This policy meets the interim complaint handling standards in Schedule 1 of the Health Complaints Act 2016 (Vic) and the RACGP Standards for general practices. It covers complaints from patients, carers and family members about any part of the practice, clinical or not.
2
Principles
Every complaint is handled so that it is:
easy to make, in the way that suits the patient
acknowledged promptly and taken seriously, however small it seems
handled fairly, with the GP or staff member concerned given a chance to respond
kept confidential, and never held against the patient in their future care
used to improve the practice, not only to close a file
3
How to make a complaint
A complaint can be made in person to reception or the Practice Manager, by phone, by email, through the feedback form in the waiting room or on the website, or by letter. Anonymous complaints are accepted and looked into, though the practice cannot reply to them. A carer or family member can complain on a patient's behalf, with the patient's consent where they are able to give it. Reception staff arrange a free interpreter through TIS National for anyone who needs one, and information about complaints is displayed in the waiting room in plain English.
4
Timeframes
Timeframes run in business days from when the practice receives the complaint. If a step will take longer, the patient is told why and given a new date.
Step
Timeframe
By
Acknowledge the complaint
Within 2 days
Practice Manager
First conversation with the patient
Within 5 days
Practice Manager
Resolve a service complaint
Within 10 days
Practice Manager
Resolve a clinical complaint
Within 30 days
Principal GP
Progress update on open complaints
Every 10 days
Practice Manager
Review of the outcome, on request
Within 10 days
Practice owner
5
How a complaint is handled
The Practice Manager owns each complaint from start to finish and follows these steps:
1.
Record the complaint in the complaints register on the day it arrives.
2.
Acknowledge it, in writing where contact details are given, with the name of the person handling it.
3.
Speak with the patient to understand what happened and what outcome they want.
4.
For a clinical complaint, arrange a review of the records by a GP who was not involved.
5.
Hear from the staff member or GP concerned, and offer them support.
6.
If care caused harm, follow the open disclosure process: acknowledge, apologise and explain what happened.
7.
Give the patient the outcome in writing, with reasons, any action taken, and how to take it further.
6
Escalation within the practice
A patient who is not satisfied with the outcome can ask for it to be reviewed by the practice owner, who has not been involved. A complaint about the Practice Manager goes straight to the practice owner, and a complaint about the principal GP is reviewed by another senior GP. The practice also refers a complaint on immediately when it raises a risk to other patients.
7
External bodies
Patients can go to an outside body at any time, without first completing this process, and the practice gives these details in every outcome letter:
Body
When to contact it
Health Complaints Commissioner (Victoria)
Any complaint about a health service, generally within 12 months of the service, or when a complaint to the practice is not resolved within 3 months
Ahpra and the Medical Board of Australia
Concerns about the conduct, health or performance of a registered practitioner
Office of the Australian Information Commissioner
Privacy complaints under the Privacy Act 1988, usually after raising them with the practice first
8
Records and confidentiality
The complaints register records the date, the nature of the complaint, the steps taken, the outcome and any change made. Complaint correspondence is kept separately from the patient's medical record, except for clinical facts that belong in the record, and is retained for 7 years. Only the people handling a complaint can see it, and a complaint is never mentioned in a referral or report about the patient.
9
Fees and billing complaints
Complaints about a gap fee, a missed bulk billing arrangement or a Medicare claim are handled under the same timeframes. Where the practice charged in error, it refunds the difference within 5 business days of finding the error and explains what went wrong.
10
When behaviour becomes unsafe
Staff are entitled to a safe workplace. If a person making a complaint becomes abusive or threatening, the Practice Manager may ask them to continue in writing only, but the complaint itself is still handled on its merits and the patient keeps access to care.
11
Learning and review
Complaints are a standing item at the monthly practice meeting, with names removed, and each one is asked the same question: what would stop this happening again? The Practice Manager reports trends to the practice owner every quarter. This policy is reviewed every two years and whenever the complaint handling standards change.

Section by section

What each section is for, so you can keep the ones you need and drop the rest.

Cover
Masthead cover with the practice, title and purpose line.
1 and 2. Scope and principles
Nine GPs, 11,000 patients, Schedule 1 and the RACGP Standards.
3. How to make a complaint
Five channels, anonymous complaints, carers and interpreters.
4. Timeframes
Six steps with a timeframe and an owner each.
5 and 6. Handling and escalation
Seven steps including open disclosure, and who reviews whom.
7. External bodies
The Health Complaints Commissioner, Ahpra and the OAIC with their triggers.
8 to 11. Records, billing, behaviour and learning
Separate files kept 7 years, billing refunds, unsafe behaviour and monthly review.

How to adapt this document

First, outside Victoria, replace the Health Complaints Commissioner with your state's health complaints body and check its time limits, since each state has its own Act. Second, set timeframes your practice can actually meet with the staff it has; a two GP practice may need 15 days for clinical complaints. Third, if you are not a health service, keep the structure and swap the external bodies table for your ombudsman, regulator or industry dispute scheme.

Which law the terms follow

The standards come from the Health Complaints Act 2016 (Vic): Schedule 1 sets the interim complaint handling standards, section 5 lets patients complain to the Commissioner when a complaint to the provider is unresolved after 3 months, and section 8 sets a 12 month limit that the Commissioner can extend. Privacy complaints follow the Privacy Act 1988, and practitioner conduct goes to Ahpra under the Health Practitioner Regulation National Law.

What makes this document work

Every step has a time and an owner

The table gives six steps a timeframe and a person: acknowledged within 2 business days by the Practice Manager, a first conversation within 5, service complaints resolved within 10, clinical complaints within 30 by the principal GP, and updates every 10 days on anything still open.

Clinical complaints get an independent look

Step 4 has the records reviewed by a GP who was not involved, step 6 applies open disclosure when care caused harm, and clause 6 sends a complaint about the principal GP to another senior GP. Patients can trust the answer because the person checking was not the person complained about.

Outside bodies are named with their triggers

The external bodies table says when to use each one: the Health Complaints Commissioner within 12 months of the service or when a complaint to the practice is unresolved after 3 months, Ahpra for practitioner conduct, health or performance, and the OAIC for privacy.

Questions people ask

Do Victorian health services have to follow complaint handling standards?

Yes. Section 131 and Schedule 1 of the Health Complaints Act 2016 (Vic) set interim minimum standards for health service providers: acknowledge complaints promptly, tell people how to complain, keep them informed, protect their personal information and keep a record of every complaint and the action taken. This policy builds its steps on those standards.

Does a patient have to complain to the practice before going to the Commissioner?

Not always. The Act lets a person go straight to the Health Complaints Commissioner where complaining to the provider would be unreasonable or inappropriate, and also when a complaint to the provider is not resolved within 3 months. This policy tells patients they can go outside at any time.

What is open disclosure?

An open conversation with a patient, and their family where appropriate, after care has caused harm: acknowledging what happened, apologising, explaining what is known, and saying what will be done to prevent it happening again. It is expected practice in Australian health care, and step 6 of this policy applies it whenever a complaint reveals harm.

Should complaints be filed in the patient's medical record?

Generally no. Clinical facts that came to light belong in the record, but the complaint itself is kept in a separate complaints file so it cannot influence future care or appear in a referral. This policy keeps complaint correspondence for 7 years and limits access to the people handling it.

How should a practice handle an abusive complainant?

Separate the behaviour from the complaint. Staff safety comes first, so the practice can limit contact, for example to writing only, but it still investigates the complaint on its merits and does not withdraw care because a complaint was made. Clause 10 sets out that balance.

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