Are you ready for new feedback and complaints requirements?
The Royal Commission into Aged Care Quality and Safety underscored the importance of feedback in identifying risks and areas for improvement, while the Charter of Aged Care Rights mandates that providers uphold older people’s rights to ‘complain free from reprisal’ and have their complaints addressed fairly and promptly. Despite this, older people, their families, and aged care staff can be hesitant to raise concerns and complaints because they worry there will be negative consequences. To create an environment where older people feel safe to speak up and make complaints, providers require robust, transparent, and person-centred feedback and complaints systems.
To provide clearer expectations, the draft Strengthened Standards, expected to come into force on 1 July 2025, build on the existing feedback and complaints standard by requiring providers to demonstrate that they:
- Acknowledge all feedback and complaints
- Manage feedback and complaints transparently
- Collect and analyse feedback and complaints data
- Report outcomes of data analysis to the governing body, older people, and staff
In addition to these new requirements in the draft Strengthened Standards, the proposed model for regulating aged care includes a new approach for managing feedback and complaints. Under the new model, providers will need to establish feedback and complaints systems that promote a positive complaints culture and drive continuous improvement. This should include a commitment to listening to, addressing, and learning from complaints, which will also help to foster a culture of continuous improvement. Systems should align with the principles underpinning Standard 1 of both the current and Strengthened ACQS to be person-centred, fair, empathetic, and culturally safe and appropriate. Providers should make sure their feedback and complaints systems are compliant with legislative requirements and documented in policies and procedures that are followed in practice. More information on this model is expected with the release of the rules that will operate under the new Aged Care Act.
What can providers do to prepare?
While we await the final approval of the new Aged Care Act and Strengthened Standards providers should take proactive steps to prepare.
The first step providers can take is to review their current feedback and complaints systems to identify potential gaps. Although the draft Strengthened Standards introduce new requirements, many providers are likely already meeting these by maintaining best practice feedback and complaints systems. Most MOA members will have assessed their current systems in November’s Feedback, Complaints, and Open Disclosure audit which provided results against both the current and strengthened ACQS.
Gaps may be more apparent when assessing current systems against the new regulatory model, in particular, requirements to demonstrate a positive complaints culture and for feedback and complaints systems to be explicitly person-centred, empathetic, and culturally appropriate. Organisational culture change takes time, so providers who start reviewing and updating their systems now will be better prepared for the implementation of the Strengthened Standards and the new Aged Care Act come 1 July 2025.
?Managing feedback and complaints with MOA – NEW module
To streamline feedback and complaints, continuous improvement, and compliance processes for providers, MOA is pleased to announce the release of its new Feedback and Complaints Module which is aligned with the requirements of the Standards, Aged Care Act, and best practice.
The module provides an easy and accessible way for anyone—older people, families, friends, visitors, and staff—to give feedback, either anonymously or with an option for follow-up contact. Verbal feedback can also be logged via a user-friendly online form on the MOA platform, ensuring everyone has an equal opportunity to share their experiences and suggestions.
All feedback, from praise to complaints, is securely stored in a centralised, confidential system with strict access controls. Efficient response tools supported by AI encourage timely, traceable communication, in line with open disclosure and transparency practices.
In addition, the module links to MOA’s PCI and incident management features, allowing feedback to seamlessly inform continuous improvement initiatives. Together, these capabilities make MOA’s Feedback and Complaints module an invaluable asset for proactive service enhancement and high-quality care.
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"The new Feedback and Complaints Module is fully integrated with the MOA platform, connecting directly to our Quality Indicator Module and PCI system. This ensures that feedback doesn't just sit idle—it’s transformed into actionable insights that drive continuous improvement and align seamlessly with a provider’s quality objectives."– Garry Neale , CEO, MOA Benchmarking
Fostering a positive complaints culture
Regardless of the system used, providers who have a positive-complaints culture see complaints as opportunities to improve safety and quality, have a better understanding of older people’s needs and preferences, and build positive, trusting relationships with older people and their families and representatives (Aged Care Quality and Safety Commission). Establishing a positive complaints culture requires alignment with strategic goals and support from leadership teams who model the behaviours of being open and transparent, listening to feedback and complaints with empathy and respect, and addressing them fairly and appropriately (Disability Services Commissioner). Providers should also engage and collaborate with all levels of staff to review their current complaints culture and identify how to improve. These aspects of a positive complaints culture align with foundational requirements for fostering a culture that values continuous improvement, with a focus on collaboration, a leadership commitment, building trust, and always looking for ways to learn and improve.
To assess your service’s current feedback and complaints culture, the Aged Care Quality and Safety Commission recommends asking yourself:
- How do you make people feel when they complain?
- Can people see positive outcomes from the complaints they've made?
- Do people see others being punished for making complaints?
- Are staff trained to view voicing concerns and complaints as positive?
- Are staff supported to address concerns and complaints?
- Are feedback and complaints fed into your continuous improvement processes?
- Are staff encouraged to ask older people if they have any problems or concerns as part of normal conversation?
??"Ensuring feedback and complaints systems are accessible and culturally safe is fundamental to meeting the standards and delivering high-quality care. Our audit programs are designed to help providers not only comply with these requirements but also foster a culture of openness and continuous improvement." – Dr Leith Heyman, PhD, Programs Director, MOA Benchmarking
Person-centred complaints systems
Providers should also evaluate whether their complaints systems are person-centred, which is essential for a positive-complaints culture. A person-centred complaints system should be ‘sufficiently flexible to respond to individual needs and consider what is important to the person using the service’. A person-centred complaints system should also be empathetic. Empathy is an important quality for those responsible for addressing complaints and could include, for example, using your voice and body language to create an environment where people feel safe and heard.
Person-centred complaints management processes should make older people feel like it is easy to make a complaint or raise a concern. Older people should be empowered to speak up, and they should feel like they are listened to and understood. At the end of the complaints process, older people should feel like they have made a difference by speaking up, which will make them feel more confident submitting complaints or other feedback again in the future (Parliamentary and Health Service Ombudsman).?
Cultural appropriateness
Cultural appropriateness and safety are essential for any feedback and complaints system. Without these, providers risk only receiving feedback and complaints from a small subset of older people. Providers should consider the cultural backgrounds of older people and those in their communities. Some older people may not be aware of their right to provide feedback and make complaints, while others may come from backgrounds where raising concerns was not safe. The type of feedback that older people feel comfortable providing can also differ, with some more comfortable providing either direct or indirect feedback.
To ensure accessibility, providers should ensure that information about making a complaint is available in older peoples’ preferred languages and that older people can make complaints in their preferred languages. Providers should also consider consulting with advocacy groups and peak bodies to review the cultural appropriateness and safety of their feedback and complaints systems.
New Feedback and Complaints Module
If you would like to find out more about our new Feedback and Complaints Module, or setup access for your service or organisation, please contact admin@moa.com.au or call 1300 760 209.