Complaints & Feedback Policy
ABLE & CO ALLIED HEALTH PTY LTD
ABN 78 697 626 430
COMPLAINTS & FEEDBACK POLICY
| Document Number | AC-COMP-001 |
|---|---|
| Version | 1.0 |
| Issue Date | 18 June 2026 |
| Review Date | 18 June 2027 |
| Classification | Public — participant-facing |
| Owner | Founder / Complaints Officer |
| Regulatory Basis | NDIS Practice Standards; UN CRPD Article 13; NDIS Quality and Safeguards Commission Guidelines |
1. Purpose
Able & Co Allied Health Pty Ltd is committed to providing accessible, fair, and effective mechanisms for participants, families, carers, and stakeholders to raise complaints and provide feedback about our services and platform. This policy ensures compliance with NDIS Practice Standard 1 (Rights and Responsibilities) and the National Disability Strategy 2021-2031.
A robust complaints framework is not merely a compliance requirement; it is a fundamental expression of respect for participant rights, consistent with the United Nations Convention on the Rights of Persons with Disabilities (CRPD), particularly Article 13 (access to justice) and Article 19 (living independently and being included in the community).
Research consistently demonstrates that effective complaints mechanisms improve service quality, restore trust, and empower participants to exercise self-determination (Chenoweth & Clements, 2014; Mansell et al., 2010).
2. Scope
This policy applies to:
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All NDIS participants receiving supports facilitated through the Able & Co platform
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Family members, carers, advocates, and nominees acting on behalf of participants
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NDIS support organisations using the Able & Co platform
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Support workers and staff of partner organisations
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Any member of the public who raises a concern about Able & Co's services
3. Legislative and Regulatory Framework
3.1 Legislation and Standards
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NDIS Act 2013 (Cth) — sections 73O–73X (complaint mechanisms)
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NDIS (Complaints Management and Resolution) Rules 2018
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NDIS Practice Standards — Standard 1.5: Feedback and Complaints
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National Disability Strategy 2021-2031 — Outcome Domain 3: Rights protection, justice and legislation
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United Nations Convention on the Rights of Persons with Disabilities (CRPD) — Articles 12, 13, 19
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Disability Discrimination Act 1992 (Cth)
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Human Rights and Equal Opportunity Commission Act 1986 (Cth)
3.2 Evidence Base — Peer-Reviewed Literature
| # | Reference |
|---|---|
| [1] | Mansell, J., Knapp, M., Beadle-Brown, J., & Beecham, J. (2007). Deinstitutionalisation and community living: Position statement. Tizard Learning Disability Review, 12(2), 43–46. Foundational research on participant rights and complaints in disability services. |
| [2] | Bigby, C., & Frawley, P. (2010). Social work practice and intellectual disability. Palgrave Macmillan. Chapter 7 addresses accessible complaints mechanisms for people with communication support needs. |
| [3] | Chenoweth, L., & Clements, N. (2014). Consumer perspectives on disability support services. Disability & Society, 29(3), 403–416. Demonstrates correlation between accessible complaints processes and service quality. |
| [4] | Shakespeare, T. (2018). Disability: The basics. Routledge. Informs rights-based approach to complaints — Chapter 5. |
| [5] | Productivity Commission. (2011). Disability Care and Support (Report No. 54). Australian Government. Foundational evidence for NDIS complaints framework design. |
| [6] | Robinson, S., & Chenoweth, L. (2011). Preventing abuse in disability services: A literature review. Department of Communities. Queensland Government. Informs serious complaint escalation protocols. |
| [7] | UN Enable. (2006). Convention on the Rights of Persons with Disabilities. United Nations. Article 13 — Access to Justice forms the normative foundation of this policy. |
| [8] | Bigby, C., Webber, R., & McKay-Brown, L. (2015). Mainstream or disability-specific? A study of residential services for older people with intellectual disabilities. Journal of Intellectual & Developmental Disability, 40(4), 392–398. |
4. Our Complaints Principles
Able & Co's complaints framework is guided by the following principles:
| Principle | Description |
|---|---|
| Accessibility | Complaints can be made in multiple formats — written, verbal, email, or through a representative or advocate — to ensure no participant is excluded due to communication support needs. |
| Confidentiality | All complaints are handled with strict confidentiality. Complainant identity is not disclosed without consent, except where required by law. |
| No Detriment | A complainant will not suffer any disadvantage, discrimination, or reduction in service quality as a result of raising a complaint. |
| Responsiveness | All complaints receive acknowledgement within 5 business days and resolution within 30 business days. |
| Natural Justice | All parties to a complaint have the opportunity to be heard before a decision is made. |
| Continuous Improvement | Complaints data is analysed quarterly to identify systemic issues and drive service improvements. |
| Rights-Based | This policy is grounded in the UN CRPD and affirms each participant's right to raise concerns without barrier. |
5. What Is a Complaint?
A complaint is an expression of dissatisfaction about:
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The quality, safety, or delivery of supports facilitated through the Able & Co platform
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The conduct of support workers, staff, or partner organisations
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A decision made about a participant's support plan or access to services
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Privacy breaches or inappropriate handling of personal information
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Discrimination, abuse, neglect, or exploitation
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A failure to respond to a previous complaint
Feedback (positive or neutral comments that do not express dissatisfaction) is also valued and recorded separately. Positive feedback is shared with relevant staff. Suggestions for improvement are reviewed quarterly.
6. How to Make a Complaint
6.1 Complaints Channels
| Method | Details |
|---|---|
| rob@ableandco.au — subject line: "Complaint" | |
| Platform | Via the Able & Co app — Feedback & Complaints button (coming in v2.0) |
| Phone | Contact number published on ableandco.au |
| Written | Able & Co Allied Health Pty Ltd, Western Sydney NSW |
| Advocate | Participants may have a support person, advocate, or nominee lodge a complaint on their behalf |
6.2 Anonymous Complaints
Anonymous complaints will be accepted and investigated to the extent possible. However, we may be limited in our ability to resolve the matter or provide a response where the complainant cannot be identified.
6.3 Information Needed
To help us resolve your complaint, please provide:
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Your name and contact details (or your advocate's details)
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A description of the issue, including dates and names of people involved
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What outcome you are seeking
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Any supporting documents or evidence
7. Complaints Resolution Process
| Stage | Timeframe | Action |
|---|---|---|
| Stage 1 | Day 1–2 | Acknowledge complaint in writing. Assign complaint ID number. Inform complainant of process and expected timeframe. |
| Stage 2 | Day 3–15 | Investigate: gather information from all parties, review records, interview relevant staff or support workers. |
| Stage 3 | Day 16–25 | Determine outcome. Draft resolution decision. Provide draft to relevant parties for comment. |
| Stage 4 | Day 26–30 | Communicate final decision in writing. Outline any actions taken or improvements implemented. |
| Stage 5 | Day 31+ | Follow up with complainant 30 days post-resolution to confirm satisfaction. |
Extensions beyond 30 business days may be necessary for complex complaints. The complainant will be notified in writing with reasons and a revised timeline.
8. Serious and Reportable Complaints
8.1 Immediate Risk
Where a complaint indicates immediate risk to the safety of a participant or others, Able & Co will:
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Contact emergency services (000) if there is immediate physical danger
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Notify the relevant NDIS support organisation immediately
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Notify the NDIS Quality and Safeguards Commission within 24 hours
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Preserve all relevant records
8.2 Reportable Incidents
The following complaint types are treated as reportable incidents under the NDIS (Reportable Incidents) Rules 2018:
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Death of a participant
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Serious injury
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Abuse or neglect
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Unlawful sexual or physical contact
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Use of unauthorised restrictive practices
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Unexplained absence from care
Reportable incidents are notified to the NDIS Commission within 24 hours (initial notification) and 5 business days (full report).
8.3 Mandatory Reporting (NSW)
Able & Co's staff and partner organisations must make mandatory reports under applicable NSW legislation where they have reasonable grounds to suspect a child or vulnerable adult is at risk of harm.
9. External Escalation
If a complainant is not satisfied with our internal resolution, they may escalate to:
| Body | Contact Details |
|---|---|
| NDIS Quality & Safeguards Commission | ndiscommission.gov.au │ 1800 035 544 │ complaints@ndiscommission.gov.au |
| Australian Human Rights Commission | humanrights.gov.au │ 1300 369 711 |
| NSW Civil & Administrative Tribunal (NCAT) | ncat.nsw.gov.au for discrimination and rights matters |
| Office of the Australian Information Commissioner | oaic.gov.au │ 1300 363 992 (for privacy complaints) |
| Community & Disability Services Complaints Commissioner (NSW) | facs.nsw.gov.au |
10. Complaints Register
All complaints are recorded in the Able & Co Complaints Register. The register captures:
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Unique complaint ID
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Date received
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Nature of complaint (category)
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Complainant details (anonymised in reports)
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Status and assigned owner
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Investigation notes
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Resolution outcome and date
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Whether escalated externally
The register is reviewed quarterly by the Founder/Complaints Officer. Trends and systemic issues are reported in the annual quality report.
Sample Complaints Register — Template
| ID | Date Received | Category | Description (brief) | Status | Resolution Date | Outcome |
|---|---|---|---|---|---|---|
| C-001 | DD Mon YY | Service Quality | [Brief description] | Open / Closed | DD Mon YY | [Outcome summary] |
| C-002 | Privacy | |||||
| C-003 | Conduct |
11. Staff Responsibilities
| Role | Responsibility |
|---|---|
| Founder / Complaints Officer | Receive all complaints; oversee investigation; make final determination; report to NDIS Commission as required; maintain complaints register; quarterly review. |
| Partner Organisation Staff | Receive and forward complaints to Able & Co within 1 business day; cooperate with investigations; maintain confidentiality. |
| Support Workers | Inform participants of their right to complain; never discourage or obstruct complaints; report concerns immediately. |
12. Continuous Improvement
Able & Co uses complaints data to drive service improvement:
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Quarterly complaints analysis — identify patterns and root causes
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Annual quality report — includes complaints summary (de-identified)
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Policy review — complaints findings inform annual policy updates
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Staff training — complaints themes incorporated into annual training content
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Platform development — systemic issues escalated to product backlog
This approach aligns with the NDIS Practice Standard requirement for continuous improvement and is supported by evidence that organisations with active complaints learning loops achieve better participant outcomes (Mansell et al., 2007).
13. Approval and Version Control
| Version | Date | Author | Approved By | Summary |
|---|---|---|---|---|
| 1.0 | 18 June 2026 | Complaints Officer, Able & Co | Complaints Officer, Able & Co | Initial issue |
_______
Able & Co Allied Health Pty Ltd — Complaints Officer
Able & Co Allied Health Pty Ltd
18 June 2026
Complaints & Feedback Policy | Version 1.0 | 18 June 2026 | ABN 78 697 626 430 Page
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