1. Purpose

The purpose of this policy is to:

1.1    This is a policy of The Doctors' Health Fund Pty Limited (‘The Fund’) ABN 68 001 417 527. 

1.2    This policy sets out the Funds commitment to the effective management of complaints and is supported by the Doctors’ Health Fund (DHF) Complaints Management Procedure.

1.3    The purpose of this policy is to:

  • ensure that complaints received by the Fund, are resolved in timely and fair manner; 
  • improve the standard of service for our members by ensuring that all complaints are addressed and, where relevant, used to improve processes;
  • provide assistance to Fund staff in dealing with complaints by establishing procedures for making complaints; and
  • advise complainants of their rights with respect to the handling of their complaint.

2. Definition

A complaint is an expression of dissatisfaction made to or about an organisation, related to its products, services, staff or the handling of a complaint, where a response or resolution is explicitly or implicitly expected or legally required (as defined by the Australian Standard AS/NZS 10002:2014 Guidelines for complaint management in organisations).

3. Guiding Principles

The Fund is committed to ensuring compliance with the Australian Standard AS/NZS 10002:2014 Guidelines for complaint management in organisations.

In accordance with the AS/NZS 10002:2014, the following guiding principles are applied by the Fund when managing complaints:

3.1     Enabling complaints

3.1.1 People focus: The Fund is committed to the efficient and fair resolution of complaints by staff at all levels, including the Chief Executive Officer (CEO) and the Board of Directors. The Fund acknowledges consumers' right to complain and encourages feedback from consumers. Complainants will be treated with respect, and will be actively involved in the complaints process as far as practicable and appropriate in the circumstances.

3.1.2 Ensuring no detriment to complainant: The Fund will take all reasonable steps to ensure that complainants are not adversely affected because of a complaint made by them or on their behalf.

3.1.3 Visibility and transparency: The Fund will make the Complaints Resolution Policy publicly available in plain language on its website and to anyone who requests it. 

3.1.4 Accessibility: The Fund’s complaint management system is accessible to everyone, and will provide support to people to make a complaint if needed. 

3.1.5 No charges: The Fund will not charge a fee where the complaint is dealt with internally. All reasonable costs incurred or to be incurred by the Complainant resulting from the decision to refer the matter to an external mediator shall be borne by the Fund. 

3.2     Managing complaints

3.2.1 Responsiveness: The Fund will maintain adequately trained staff to handle the complaint management system. The Fund will deal with complaints quickly and treat complainants courteously. The Fund will advise the complainant about -
(a)     the complaint process;
(b)     the expected timeframes for its actions;
(c)     their likely involvement in the process; and
(d)     the possible or likely outcome of their complaint, where practicable.

3.2.2 Objectivity and fairness: The Fund recognises the need to be fair and objective in its assessment of the complaint and to manage the process in an unbiased manner. Fairness applies to all parties, including the complainant, the Fund membership as a whole and any individual against whom a complaint may be raised. Each complaint shall be addressed in an equitable, objective and unbiased manner through the complaints-handling process. 

3.2.3 Equity: All complaints should be addressed in an equitable manner and in accordance with this policy. 

3.2.4 Privacy and disclosure: Personally identifiable information (as per the Privacy Act 1988) concerning the complainant shall be actively protected from disclosure, unless the member or complainant expressly consents to its disclosure. The Fund deals with the personal information it collects according to its privacy policy. Our privacy policy is available on our website at https://www.doctorshealthfund.com.au/privacy-policy If you wish to have a paper copy of the policy please call (02) 9260 9000 or 1800 128 268. If you would prefer to have someone else make a complaint on your behalf, we will require your written confirmation that you have authorised another person to pursue the complaint. This is so we do not breach your privacy when we discuss your complaint with them. 

3.2.5 Communication: To minimize complaints and facilitate early resolution, the Fund will provide explanations for policies, procedures and decisions in its communication with complainants and its staff.

3.3     Managing the parties

3.3.1 Conduct of parties: The Fund will implement policies and procedures that make clear the behaviour expected of both its staff and complainants. The Fund requires the cooperation of the complainant in all matters concerning the complaint and looks forward to timely submission by the complainant of statements, documents and other evidence that may be reasonably required by the Fund in resolving the complaint. All associated reasonable costs shall be borne by the Fund. 

3.3.2 Work health and safety: The Fund will develop, adopt and implement appropriate policies, procedures and practices to ensure the health and safety of its staff involved in complaint management, including identity protection if required.

3.3.3 Complaint involving multiple parties: When a complaint involves multiple organisations or multi areas within the organisation, consideration should be given to options for coordinating communication with the complainant. Subject to privacy and confidentiality obligations, communication and information exchange between the organisations should be pre-arranged, where practicable and appropriate, to facilitate investigation and response to a complaint. 

3.3.4 Empowerment of staff: The Fund will ensure that staff are properly empowered to implement its complaint management system as relevant to their role and encourage staff feedback as being a valuable source of insight into problems with the organisation, its products, services or the complaint management system.

3.4     Accountability, learning and prevention

3.4.1 Accountability: The Fund will apply appropriate reporting on the operation of the complaints resolution process against documented performance standards. 

3.4.2 Continuous improvement: The Fund will review its processes or products or retrain staff as appropriate and where the complaint involves a systemic or recurring issue. 
3.4.3 Prevention of ongoing disputes: The Fund will develop and implement systems that minimize the possibility of complaints escalating into ongoing disputes.3.4.4 Remedies: The Fund has the capacity to determine and implement remedies.

3.4.5 Data collection: The Fund will record and monitor the status of complaints.

3.4.6 Review: The Fund will review this policy annually.

4. Complaints-management framework

4.1     The Fund has a complaints management system, policy and procedure in place to log, monitor and report complaints. 

4.2     This policy and the DHF Complaints Management Procedure are readily accessible to all staff.

4.3     Complainants may make complaints in whichever way they feel most comfortable: by email, letter, fax, face-to-face or telephone. In order to clarify the exact nature of the grievance, it is usually preferable for the complainant to put the complaint in writing. All complainants must be sent an acknowledgment of receipt of their complaints.

4.4     Where unresolved immediately, the complainant should be advised that they will be contacted within three (3) business days of receipt of the complaint, and advised of the progress of their complaint.
4.5     The complaint must, where practicable, be resolved within ten (10) business days. In any event, the complaint must be resolved within forty five (45) calendar days from the date of receipt of the complaint.

4.6     The complainant must be informed of the criteria and complaints handling process, including the avenues for further review internally and/or externally through the Private Health Insurance Ombudsman (PHIO). Contact details for the PHIO are provided at the end of this policy.

4.7     Where possible, complaints should be reviewed by a staff member who has not been involved in the matter. Ideally, if the complaint is about the quality of service, the CEO should independently review the complaint.

4.8     If the complainant is dissatisfied with how their complaint is being addressed or the outcome of their complaint, they will have the option of escalating their complaint to a Team Leader/Manager. 

4.9     Where complaints cannot be resolved internally, or if the complainant is dissatisfied with any of the decisions made by the Fund or is dissatisfied with the handling of the their complaint or no such decision is notified to the complainant within forty five (45) calendar days of the complaint, they will have the option of referring the matter to the PHIO.

4.10     The Fund will take all reasonable steps to resolve the dispute.

5. Contacting the Fund

Free Call: 1800 226 126 (8:30am to 6:00pm Monday to Friday)
Email: info@doctorshealthfund.com.au
Website: https://www.doctorshealthfund.com.au
Fax: (02) 9260 9958
Post: Head of Member Experience and Operations
The Doctors' Health Fund Pty Ltd
PO Box Q1749, Queen Victoria Building
Sydney NSW 1230

6. Private Health Insurance Ombudsman (PHIO) Contact details

Where complaints cannot be resolved internally, complainants retain the right to refer the complaint to:

The Private Health Insurance Ombudsman (PHIO)
Complaints Hotline: 1300 362 072 (between 9:00am to 5:00pm Monday to Friday) 
(option 4 for Private Health Insurance)
Email: phio.info@ombudsman.gov.au
Website: http://www.ombudsman.gov.au
Fax: (02) 6276 0123
Post: Private Health Insurance Ombudsman
Office of the Commonwealth Ombudsman
GPO Box 442
Canberra ACT 2601