QO 10 Steps to Effective CMS V4

8/20/2019 QO 10 Steps to Effective CMS V4

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1. What is a CMS?

A CMS is a staged way of receiving, recording, resolving,

responding to and reporting on complaints.

A complaint is simply one form of feedback. Other forms of

feedback include service requests, information and documentrequests, enquiries, suggestions, compliments.

One of the key differences between a complaint and another

form of feedback is that a complaint involves a person

expressing dissatisfaction, either verbally or in writing, about

a decision, action or service provided (or not provided) by a

council or its staff. The other forms of feedback don’t include

any indication of dissatisfaction. An effective CMS should:

Æ Provide a simple and clear process (to staff and public),

fair and timely complaint outcomes and information to

help improve service delivery.

Æ

Include written policy and procedures, a complaintsrecording and reporting system and other resources

including trained staff and website.

Æ Meet recognised standard and principles of good

complaints management practice.

Under the Local Government Regulation (LGR) s306 each

council is required to adopt, a complaints management

process for resolving administrative action complaints. This

statutory complaints management process is a CMS. The

requirements for this process (CMS) are outlined in LGR s306.

2. Why would an effective CMS be valuable to

your council?

People have a right to complain and the community expects

that councils will be customer-focused and responsive to

feedback, particularly complaints. An effective CMS is an

integral part of quality customer service and the accountability

process. It should provide tangible benefits for councils, staff

and in particular the community. Benefits of an effective

CMS include:

Æ providing a structured and consistent approach to

complaints management across council

Æ promoting customer satisfaction

Æ enabling poor decisions/actions to be rectified quickly

and efficiently

Æ saving money by resolving complaints internally, close

to the source

Æ preventing complaints from unnecessarily escalating,

a situation which can be resource intensive and lead to

adverse publicity

Æ identifying areas, practices, procedures and services for

improvement

Æ satisfying council’s statutory obligation to implement a

complaints management process.

One of the major returns on investment in an effective CMS

should be administrative and service improvements to benefit

individuals and the community.

3. Review your council’s current process of

managing complaints

Councils make important decisions and provide vital services

to their communities.

Complaints are inevitable for any organisation dealing withthe public. Accordingly, your council will be dealing with

complaints even though it may not have a formal or approved

CMS, meeting legislative requirements and other recognised

standards of good complaints management.

Your council’s current process of complaints management is

relevant and should inform any development or enhancement

of an effective CMS. The review of the current process should

identify, for example:

Æ What are the main types and sources of complaints?

Æ Is the complaints process is communicated to staff, the

community and complainants and, if so, how?

Æ How are complaints managed from receipt to

resolution or finalisation?

Æ What staff and other resources are used in managing

complaints?

Æ What authority and training staff have to manage and

resolve complaints?

Æ Are complaints recorded and reported on and if so, how?

Æ Is complaints data used to identify and rectify systemic

and recurring problems?

Æ Is management involved in reviewing and monitoring

the effectiveness of the CMS?

Æ Is management and staff committed to effective

complaints management?

Æ What is the council’s complaints culture? Are complaints

viewed negatively or positively?

The QOO ‘Effective Complaints Management Self-

Audit Checklist’ is designed to help councils and other

agencies review their current complaints processes and

to identify improvements. This checklist is available at

the QOO website at http://www.ombudsman.qld.gov.

au/PublicAgencies/EffectiveComplaintsManagement/

ComplaintsManagementResources.aspx

4. Commit to an effective CMS

The review of your council’s current complaints process should

provide a good indication of its commitment to complaints

management.

An effective CMS requires a strong commitment by

management and staff to make it work.

Complaints management should be taken seriously and seen

as integral to good customer service. Complaints should be

welcomed and viewed positively as providing an opportunity

to review and improve council’s performance.

In particular, councils should have a commitment to

recognised or guiding principles of good complaints

management (AS ISO 10002-2006 Customer satisfaction –

Guidelines for complaints handling in organisations refer).

These principles are:

10 steps to developing an effective Complaints

Management System (CMS)Councils



Æ visibility- information about how and where to

complain should be well publicised to customers, staff

and the public

Æ accessibility - the CMS process should be easily

accessible to all complainants

Æ responsiveness - complaints should be acknowledged,

and addressed promptly in accordance with their

urgency

Æ objectivity - each complaint should be addressed in an

equitable, objective and unbiased manner through thecomplaints process

Æ charges - there should be no charge for access to the

complaints process

Æ confidentiality – personal information concerning the

complainant should be used only for the purposes

of addressing the complaint and protected from

disclosure unless the complainant agrees to the release

Æ customer-focused approach – customer-focused

approach should be adopted, open to complaints

and show commitment to resolving complaints by its

actions.

Æ accountability – accountability for and reporting oncomplaint decisions and actions is clearly established

Æ continual improvement – continual improvement of the

CMS and services is a key objective.

It is also important that councils are committed to ensuring

compliance with the statutory requirements of the

administrative action complaints process. (LGR s306 & s187

refers). These requirements include:

Æ adopting a complaints management process and

supporting written policy and procedures

Æ placing the complaints management process (including

policy and procedures) on the council website and atits office.

Æ recording all complaints

Æ responding quickly and efficiently to complaints in a

fair and objective way

Æ informing complainants of the complaint decision and

reasons

Æ internal reporting to senior management on complaint

trends and monitoring effectiveness of the CMS

Æ external reporting on the operation and performance

of the cms in council’s annual report.

Your council’s commitment to an effective CMS should be

clearly stated and available e.g. in the approved CMS policy

and on your council’s website. However, the key is putting

commitments into operation.

5. Determine the CMS objectives

An effective CMS should have clearly stated and defined

objectives. The objectives should be determined by

considering recognised principles of good complaints

management and relevant statutory requirements. The

objectives of an effective CMS should generally address:

Æ complaints visibility and accessibility (e.g. complaints

process and related information is easily visible and

accessible to the community, customers and staff )

Æ complaints resolution process (e.g. complaints process

is fair, all relevant information is considered and

affected people are afforded a fair hearing)

Æ complaints resolution timeliness (e.g. complaints are

promptly handled within expected timeframes)

Æ complaints resolution outcomes (e.g. correct complaint

outcomes are achieved and reasonable remedies to

rectify complaints are implemented)

Æ complaints monitoring (e.g. complaints data is used to

identify improvements to decision-making, practices

and service delivery).

Clarifying the CMS underlying principles and objectives at the

outset should inform the overall direction and development

of the CMS. In particular, the CMS principles and objectives

should be considered in determining the substance, form and

complexity of the CMS that will best suit your council.

6. Determine the substance, form and

complexity of the CMS

Each council has flexibility to determine the substance, formand complexity of their CMS. The LGR doesn’t require a council

to adopt a complex or detailed CMS. It requires only that a

council’s CMS comply with certain requirements.

A good CMS is one that provides a simple and fair process that

is clear to the public and staff and meets good complaints

management principles and statutory requirements. This

approach recognises that the ‘one size fits all’ CMS is not

effective. Councils should develop a CMS that suits their own

needs. In determining the substance, form and complexity of

the CMS, councils should have also have regard to:

Æ their size

Æ the nature of functions and services provided

Æ geographic distribution of council offices

Æ the source of complaints

Æ the volume and type of complaints.

Integral to the substance, form and complexity of the CMS is

the complaints model. The complaints model is essentially

the complaints handling stages in the CMS. The LGR doesn’t

prescribe a particular complaints model. It is important that

each council adopt a suitable model.

Generally, a two stage internal model may suit smaller

councils. This model has an initial frontline stage and an

internal review stage. The frontline stage is where staff

have authority to deal with specified low-level complaints.

The internal review stage handles unresolved or referred

complaints from the frontline (stage1) by way of an

independent merits review. Complaints unresolved at stage

two should be advised of the external review right to the

Queensland Ombudsman.

Alternatively, smaller councils may adopt a centralisedmodel i.e. where all complaints are referred to one person

for management e.g. the Deputy CEO or CEO. Unresolved

complaints may then be referred to the council for

consideration or to the Queensland Ombudsman for external

review.



For further information about complaints management

models refer to the QOO ‘Effective Complaints Management

Fact Sheet Series’.

Having reviewed your current process, committed to

recognised principles of good complaints management, and

determined your CMS objectives and model, you are now in

a position to develop your CMS policy, procedures, recording

and reporting system and other resources.

7. Preparing a CMS policy

An effective CMS should be supported by an approved written

policy. LGR s306 requires the administrative action complaints

process be supported by written policy. Each council is

required to adopt a CMS policy.

A CMS policy shouldn’t be a lengthy document. Its purpose is

to set out the direction of council’s complaints management

approach. It should explain the strategic intent i.e. the ‘why’ of

council’s commitment to the principles underlying the CMS. A

CMS policy document should include:

Æ policy name

Æ policy approval (date and council resolution)

Æ policy review date/period

Æ legislative authority (LGA s268 & LGR s306)

Æ commitment to recognised good complaints

management principles

Æ policy objectives

Æ scope/application of the policy

Æ complaints model

Æ CMS elements (and associated principles) – externalvisibility and accessibility , internal communication

and training, complaints resolution, feedback, internal

reporting, monitoring effectiveness and external

reporting

Æ roles and responsibilities

Æ definitions – key terms

CMS policy elements

External visibility and accessibility is about providing

customers and the public with readily available information

about, and easy access to, a council’s CMS. Council websitesare an important channel in this regard and should include

general complaints information, the CMS policy and

procedures and online or other electronic complaints access.

[ The LGR s306 requires each council to ensure their CMS

including related policy and procedures are available on

their website.]

Internal communication (visibility) of the CMS, and training

on effective complaints management principles including

CMS policy and procedures, are critical to staff awareness

and understanding of the CMS. Staff are the most important

resource in an effective CMS. [The LGR s306 doesn’t specifyany requirements on internal communication or training on

the CMS.]

Effective complaints resolution is about achieving right

outcomes in a fair and timely way and providing meaningful

responses. Central to effective complaints resolution is the

receiving, recording, assessing, reviewing and responding

stages of the complaints process. [ The LGR s306 requires

council CMS’s to quickly and efficiently respond to

complaints in a fair and objective way and inform an

affected person of the complaint decision and reasons.]

Internal reporting is about collecting and analysing

individual or aggregate complaints data to highlight

complaint trends, systemic or recurring issues and to identify

improvements. [ The LGR s306 requires internal reports to be

provided about the operation of the CMS and mechanismsto be in place to identify, analyse and respond to complaint

trends.]

Monitoring effectiveness is about reviewing regularly the

operating effectiveness/performance of the CMS. Reviewing a

CMS should include evaluating the policy and procedures and

other elements of the system, auditing resolved complaints for

data accuracy, compliance with procedures and correctness of

outcomes, and consulting staff, customers and complainants.

[ The LGR s306 requires each council to monitor the

effectiveness of the CMS e.g. by monitoring the time taken

to resolve complaints.]

External reporting of the CMS is important for accountability

and transparency purposes. Councils should publicly report

on the operation and performance of CMS’s in annual reports.

[ The LGR s187 requires each council annual report to contain

information about the implementation and performance of

the CMS including complaints statistics.]

Importantly, the CMS policy should be consistent with and

incorporate relevant statutory requirements (LGA s268, LGR

s306, and s187). The CMS policy is the primary overarching

internal document governing the CMS. It provides the basis fordeveloping the CMS procedures.

For further information about developing CMS policy refer

to the QOO ‘Guide to Developing Effective Complaints

Management Policies and Procedures’ and ‘Effective

Complaints Management Fact Sheet Series’.

8. Preparing CMS procedures

An effective CMS should be supported by approved

procedures. LGR s306 requires the administrative action

complaints process be supported by written procedures.

Councils are required to adopt CMS procedures. CMS

procedures should be consistent with and incorporate the

statutory requirements. They should also be consistent with

the CMS policy.

The CMS procedures document is necessarily longer than the

policy and describes the steps involved in achieving the CMS

policy’s objectives. In particular, the CMS procedures should

outline the steps involved in handling complaints. However,

they can’t cover every situation. Generally, CMS procedures

document should include:

Æ procedures name Æ approval (date and council resolution)

Æ procedures review date/period

Æ legislative authority (LGA s268 & LGR s306)

Æ scope/application of the procedures



Æ complaint model - stages

Æ complaints resolution procedures – receiving,

recording, assessing, investigating/reviewing and

responding

Æ procedures for internal complaints reporting,

monitoring CMS effectiveness, external (annual)

complaints reporting

Æ roles and responsibilities

Æ

definitions – key terms.For further information about developing CMS procedures

refer to the QOO ‘Guide to Developing Effective Complaints

Management Policies and Procedures’ and ‘Effective

Complaints Management Fact Sheet Series’.

9. Establishing a CMS recording and reporting

system

Complaints management is an essential part of a council’s

decision-making and service delivery to individuals and the

community. The LGR (s306) requires all complaints to be recorded

(regardless of where or how a complaint is made to council or

how quickly a complaint may be resolved). It also requires that

councils have mechanisms in place to identify, analyse and

respond to complaint trends with internal reports to senior

management about the CMS operation.

Accordingly, complaints must be recorded and reported on for

statutory, accountability and business improvement purposes.

Your council’s CMS policy and procedures should reflect

these requirements and provide further guidance to staff on

complaints recording and reporting.

A complaints recording and reporting system doesn’t have to

be complex or expensive database or other electronic system.

Effective complaints recording and reporting system should

meet council’s individual needs and structure and may be as

simple as a spread sheet.

However, any system implemented by a council should be

able to capture key complaints information in sufficient detail

to support the analysis of complaints data for the purpose

of identifying business/service delivery improvements. Key

complaints information includes: Æ complainant’s details - name, address, contact

Æ date and how complaint received

Æ nature of complaint - subject matter/issue, outcome/s

sought

Æ significant actions taken to progress and resolve complaint

Æ complaint outcome - substantiated, unsubstantiated,

partly substantiated

Æ date complaint finalised - resolution timeframe

Æ resolution type - remedies to rectify complaint.

Overall, the system should be able to record and monitor

complaints, capture sufficient meaningful complaints

information to identify, analyse and respond to complaint

trends, identify improvements and produce reports for

consideration by senior management. For example, complaint

reports should:

Æ Set out complaint numbers and outcomes (for different

complaint types).

Æ Provide comparisons with previous periods to highlight

any trends, recurring or emerging issues.

Æ Identify any significant or systemic issues requiring

attention.

Æ Outline any potential improvements.

For further information on complaints recording and reporting

systems refer to the QOO ‘Effective Complaints Management

Fact Sheet Series’.

10. Developing other resources

Competent complaints handling staff and readily visible and

accessible CMS on the website are important CMS resources.

All staff should be made aware of the existence and operation

of the CMS e.g. by email, induction programs. Also, staff

involved in complaints handling should be trained on

the operation of the CMS, particularly the CMS policy and

procedures and their roles/responsibilities.

A council’s website is an important channel for people to make

complaints. The CMS and related policy and procedures must

be available on a council’s website (LGR s306 refers). However,

your website should also include:

Æ a clearly identifiable complaints link on the homepage

to a complaints page

Æ a complaints page providing general information about

the CMS

Æ online, email or other electronic complaints access.

For further information on internal communication and

training on the CMS to staff and website complaints visibility

and accessibility refer to the QOO ‘Effective Complaints

Management Fact Sheet Series’.

Want to know more?

The Queensland Ombudsman offers training in Complaints

Management, Good Decisions, Administrative Investigations

and Ethical Decision-Making. You can find an outline of these

programs in our training book at:

http://www.ombudsman.qld.gov.au/Portals/0/Training_

Workbook_June2012.pdf

Access QOO’s Complaints Management resources

at: http://www.ombudsman.qld.gov.au/

PublicAgencies/EffectiveComplaintsManagement/

ComplaintsManagementResources.aspx

Documents

QO 10 Steps to Effective CMS V4